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fact and that respondent is entitled to summary judgment as a
matter of law.
Background
The record establishes or the parties do not dispute the
following:
A. The Corporation’s Tax Deficiency
On September 15, 1999, respondent timely mailed to ABC
Seamless Siding & Guttering, Inc. (the corporation), a notice of
deficiency. In the notice, respondent determined that for its
taxable year ending December 31, 1995, the corporation had an
income tax deficiency and related penalties totaling $75,767.50.
In response, the corporation timely petitioned this Court at
docket No. 18699-99 (the corporation’s deficiency case).
On February 15, 2001, this Court entered a stipulated
decision in the corporation’s deficiency case, determining that
there was a $41,873 deficiency in the corporation’s income tax
for the taxable year 1995. The stipulated decision was signed
for the corporation by the same counsel who represents
petitioners in the instant cases.
B. Statutory Notices of Transferee Liability
On October 11, 2000, respondent mailed to petitioners
substantially identical statutory notices of liability,
determining that each petitioner was liable as a transferee of
the corporation for its income taxes and penalties in the amount
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