Mary Catherine Pierce - Page 8

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          partnership.  The capital contributions of the general partners             
          were $5,000 each, and petitioner’s capital contribution was                 
          $490,000.  Petitioner made her $490,000 capital contribution                
          after the Pierces had received substantial income tax refunds               
          based on the claimed losses.                                                
               On January 28, 1993, Seth Co., Inc. (Sethco), was                      
          incorporated with Mr. Pierce as its president and petitioner’s              
          son, Derek Pierce, as its sole shareholder.  Sethco’s place of              
          business was 5 Amanda Drive in Manchester, Connecticut.  Both               
          petitioner’s son and Mr. Pierce received annual salaries from               
          Sethco.  In exchange for assuming Derek Seth’s trade debt to                
          subcontractors, Sethco received Derek Seth’s heavy equipment,               
          some office equipment, and the use of Derek Seth’s business name.           
               On May 13, 1998, petitioner transferred her interest in                
          properties at 9 Deanne Lynn Circle and at 2643 Day Hill Road to             
          DDC.  Petitioner received $1 in consideration for each transfer.            
          The Day Hill Road property was destroyed by fire on June 1, 1998.           
          The insurance proceeds were distributed as follows:  (1) The                
          mortgage holder was paid the balance due on the mortgage, (2)               
          $77,710 was paid to DDC, and (3) $97,000 was paid to Sethco for             
          loss of contents.                                                           
               On May 15, 2000, Sethco conveyed property at 5 Amanda Drive,           
          Manchester, Connecticut, to DDC in exchange for a $300,000                  
          payment, which represented the property’s fair market value.                






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