Kevin B. Kimberlin and Joni R. Steele, et al. - Page 8




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               Spencer Trask did not report, on its originally filed 1995             
          return, income from the receipt of warrants, nor did it report              
          income from the exercise of the warrants on its 1997 return.  In            
          March 1998, Spencer Trask filed an amended return relating to               
          1995 and reported $13,500 of income relating to the receipt of              
          the warrants.  On February 16, 2005, respondent mailed a notice             
          of deficiency to Spencer Trask.  The notice of deficiency                   
          determined that, pursuant to sections 83 and 61, the warrants               
          received by Spencer Trask resulted in $43,950,000 of taxable                
          income in 1997 (i.e., the year the warrants were exercised).                
               Mr. and Mrs. Kimberlin did not report income from the                  
          receipt of warrants on their originally filed 1995 return, nor              
          did they report, on their 1997 return, income from the exercise             
          of the warrants.  In March 1998, Mr. and Mrs. Kimberlin filed an            
          amended tax return relating to 1995 in which they reported                  
          $76,500 of income relating to the receipt of the warrants.  On              
          September 24, 2004, respondent mailed separate notices of                   
          deficiency to Mr. and Mrs. Kimberlin.  The notices of deficiency            
          determined that in 1997 Mr. Kimberlin received a dividend from              
          Spencer Trask of $36,625,000 relating to the exercise of                    
          warrants.                                                                   
               After Mr. Kimberlin received warrants pursuant to the terms            
          of the SRA, the warrants were reissued, in accordance with Mr.              








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