- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011