Dori R. Merriam, Transferee - Page 8

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          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               
               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,              

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