- 8 - D. The Tax Court Case Napa reported an unpaid tax liability of $474,363 on its corporate income tax return for its year ending September 30, 1986. Respondent determined that petitioner was liable as a transferee of Napa. Respondent sent a notice of transferee liability to petitioner’s Tiburon residence and a copy to Ted Merriam in Colorado. James Merriam asked Ted Merriam to represent petitioner in this case, and Ted Merriam agreed. James Merriam told Ted Merriam to send the legal bills related to this case to James Merriam. Ted Merriam timely filed a petition in this case in 1992. He sent copies of all documents related to the case in envelopes addressed to James Merriam or petitioner. He designated Denver as the place of trial, and he listed petitioner as a witness in his pretrial memorandum. The case was submitted fully stipulated under Rule 122 in 1994. Ted Merriam signed the stipulation of facts without discussing it with petitioner. In an opinion filed in this case on September 6, 1995, we found that petitioner was the sole director and shareholder of Napa, James Merriam made all decisions for her regarding Napa, she had borrowed money from Napa as shown by promissory notes bearing her signature, she caused Napa to be liquidated, and, as part of the liquidation,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011