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SCOTT v. COMMISSIONER

Docket No. 5245-95.

76 T.C.M. 940 (1998)

T.C. Memo. 1998-426

Thomas H. Scott and Lynn D. Scott, Transferees v. Commissioner.

United States Tax Court.

Filed November 30, 1998.

Attorney(s) appearing for the Case

Thomas G. Hodel, for the petitioners. William R. Davis, Jr. and Jerry L. Leonard, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

In separate notices of transferee liability (notices), respondent determined that petitioner Thomas H. Scott (Mr. Scott) and petitioner Lynn D. Scott (Ms. Scott) are liable as transferees of Mountain States Stock Transfer Agents, Inc. (MSSTA) (1) in amounts not exceeding $104,580 and $95,072, respectively, for MSSTA's unpaid Federal income tax (tax) liability for 1989 of $164,981 (MSSTA's unpaid tax...

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