- 7 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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