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liability for Federal income taxes of $136,903, and additions to
tax pursuant to sections 6653(b)(1) and 6661 of $102,677 and
$34,226, respectively.
The issue for decision is whether petitioner is liable as
the transferee of assets of ACT under section 6901 and, if so,
the amount of his liability.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
The parties submitted this case fully stipulated without
trial.2 The stipulation of facts is incorporated herein by this
reference. When he petitioned the Court, petitioner resided in
Panama City, Florida.
In 1985, petitioner, Franklin W. Briggs (Briggs), John L.
Daniell (Daniell), and Michael Roy Gay (Gay) incorporated ACT, a
Florida corporation that they owned equally. They organized ACT
to provide cable television services to a beach resort in Panama
City Beach, Florida, where ACT acquired cable television
franchise rights. Petitioner was a shareholder, director, and
officer of ACT.
2 By joint stipulation, the parties agreed to be bound by
the testimony and documentary evidence offered at the trial of
Briggs v. Commissioner, T.C. Memo. 2000-380, also decided today.
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