- 4 -
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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