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The final liquidating distribution of SOAI was made on
August 18, 1986, solely to John Cidulka in the amount of
$6,038,820. SOAI retained cash in the amount of $831,394 to pay
income taxes for the taxable year ended October 31, 1986, and any
other remaining liabilities. No distributions were ever made to
John Joseph or Lauren. Neither John Joseph nor Lauren ever
received any benefits or distributions from his or her purported
stock interests in SOAI.
On December 23, 1986, John Cidulka entered into an
assignment agreement with SOAI to assume the entire obligation on
the promissory note given to decedent for his stock. Immediately
after John Cidulka assumed the obligation on the promissory note,
decedent forgave $20,000 on the principal of the promissory note.
Although each grandchild of decedent, John Joseph and
Lauren, owned 16 of the 430 shares outstanding when SOAI was
dissolved, they assumed no portion of the promissory note.
The fair market value of the promissory note, based on the
self-canceling clause in the note, was $307,381.09 on January 25,
1982.
SOAI was incorporated in the State of Indiana, which was the
major area in which it operated its outdoor advertising business.
SOAI had signs located in northwest Indiana in Lake, Porter, and
LaPorte Counties, and in a few locations in Cook County,
Illinois. The principal cities in Lake County are Gary, Hammond,
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Last modified: May 25, 2011