Don C. Reser and Rebecca Jo Reser - Page 4

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          submitted financial statements to Frost Bank.  The credit line               
          was documented by 14 promissory notes, each payable 90 days after            
          execution.  They were dated from October 7, 1985, through January            
          10, 1989.  The final note, dated January 10, 1989, states a                  
          cumulative principal loan balance of $467,508.54.  Petitioner and            
          DRPC were jointly and severally liable on the notes for repayment            
          of the loan.                                                                 
               The loan was not collateralized with any property of                    
          petitioner or DRPC.  On November 16, 1986, a guaranty agreement              
          was executed by petitioner, DRPC, and Don Test, under which Don              
          Test would guarantee the loan for a fee of $14,998.50 for each               
          90-day period that the guaranty was outstanding.  Petitioner and             
          DRPC were jointly and severally liable to Don Test for payment of            
          the fee.  Frost Bank would have granted the line of credit to                
          either petitioner or DRPC individually, but to neither without               
          Don Test's guaranty.  In addition to the guaranty, Don Test                  
          provided common stock of the Genuine Parts Co. as collateral.                
          Don Test was not a shareholder or otherwise related to the                   
          corporation.  DRPC paid the guaranty fees and claimed $60,994 and            
          $59,994 as expenses on its income tax returns for 1987 and 1988,             
          respectively.  It does not appear that petitioner paid any part              
          of the guaranty fees.                                                        
               Petitioner had total discretion as to the use of the                    
          proceeds, and Frost Bank did not monitor such use.  The line of              
          credit was used both as a source of operating capital for DRPC               




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