Mary Catherine Pierce - Page 7

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          penalties on account of their good faith reliance on their                  
          accountants.  See Pierce v. Commissioner, T.C. Memo. 1997-411.              
          On November 14, 1997, the Court entered its decision, and on                
          March 23, 1998, respondent assessed the deficiencies pursuant to            
          this Court’s decision.                                                      
               On January 24, 1995, after the petition had been filed                 
          regarding the disallowance of the losses that generated the                 
          Pierces’ refunds, Mr. Pierce transferred to petitioner the title            
          to property located at 9 Deanne Lynn Circle for $1.  The property           
          was encumbered by a mortgage held by Ulster Savings Bank with a             
          balance of $184,605 as of January 10, 1996.  On November 12,                
          1997, after this Court’s opinion and 2 days before entry of the             
          decision holding the Pierces liable for large income tax                    
          deficiencies, Mr. Pierce transferred business property located at           
          2643 Day Hill Road in Windsor, Connecticut, to petitioner for no            
          consideration.  The Day Hill Road property was encumbered by a              
          mortgage of $197,000, held by the Savings Bank of Manchester.               
               On October 31, 1991, MCU Financial Corp. (MCU) was                     
          incorporated as a C corporation.  Petitioner has been the sole              
          shareholder and president of MCU from its inception.                        
               On November 27, 1992, DDC Limited Partnership (DDC) was                
          formed.  The general partners were Derek and C. David Weeks, each           
          of whom held a 1-percent interest in the partnership. Petitioner            
          was the only limited partner, with a 98-percent interest in the             






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