- 4 - On June 4, 1982, petitioner borrowed $130,000 from the Hickman corporation profit-sharing plan (1982 plan loan). That loan, which was unsecured, was evidenced by a note payable to that plan and signed by petitioner (1982 note). The 1982 note provided that interest on the 1982 plan loan was to be paid annually at the rate of 15 percent per year, but it did not specify a repayment date for that loan. On January 4, 1984, petitioner purchased 20,000 shares of stock of National Bank of Harrah at $12 a share. During 1984, petitioner sold 200 shares of that stock. In July 1984, the National Bank of Harrah stock was converted to common stock (Harrah Bancshares stock) in Harrah Bancshares, a holding com- pany. At the time of conversion, petitioner owned 19,800 shares of Harrah Bancshares stock, or 20.43 percent of its outstanding stock. From July 1984 through about April 6, 1993, petitioner held varying amounts of Harrah Bancshares stock. In an attempt to repay the 1982 plan loan, on August 19, 1985, petitioner transferred to the Hickman corporation profit- sharing plan 5,000 shares of Harrah Bancshares stock (Harrah Bancshares profit-sharing plan stock) and certain real property located in Oklahoma County, Oklahoma (Hickman real property). (Those transfers of 5,000 shares of Harrah Bancshares stock and the Hickman real property shall be referred to collectively as the 1985 stock and real property transfer.)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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