Dale L. Oyer, Transferee, et al. - Page 4

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          of $94,738.85 for the taxable year ending December 31, 1995.3  In           
          response, petitioners filed substantially identical petitions               
          with this Court in the following cases (the transferee liability            
          cases):  Dale L. Oyer, docket No. 673-01; Acme Leasing Trust,               
          docket No. 674-01; Shirley J. Oyer, docket No. 675-01; and ABC              
          Seamless Trust, docket No. 676-01.                                          
          C.   Stipulated Decisions in Petitioners’ Transferee Liability              
          Cases                                                                       
               On March 2, 2001, before respondent had filed an answer in             
          any of the transferee liability cases, this Court entered                   
          stipulated decisions in those cases, determining that each                  
          petitioner was liable as a transferee of assets of the                      
          corporation in the amount of $58,008 plus interest as provided by           
          law from March 15, 1996, to the date of payment.4  Each                     
          stipulated decision was signed for the petitioner by the same               
          counsel who represents petitioners in the instant cases.                    






               3 This amount represents the corporation’s $75,767.50                  
          deficiency and related penalties, as determined in the                      
          corporation’s notice of deficiency, plus an additional $16,135              
          attributable to the corporation’s reported but unpaid tax                   
          liability and a $2,836.35 penalty with respect thereto.                     
               4 Ostensibly, this amount represents the sum of the                    
          corporation’s $41,873 deficiency, as determined in the stipulated           
          decision entered in the corporation’s deficiency case, and the              
          corporation’s $16,135 reported but unpaid tax liability, as                 
          referenced in the preceding note.                                           





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