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$268,027.48 (1991 interest payment). The 1991 interest payment
was calculated based on 15-percent simple interest and 9-percent
interest compounded annually on the 15-percent simple interest.
The 1991 settlement indicated that other documentation was
enclosed therewith, including (1) a copy of a quitclaim deed
dated October 17, 1991, whereby the Hickman corporation profit-
sharing plan transferred the Hickman real property to The French
Hickman Trust (Hickman revocable trust), (2) a copy of an assign-
ment by the Hickman corporation profit-sharing plan to the
Hickman revocable trust of the Harrah Bancshares profit-sharing
plan stock, (3) Form 870, Waiver of Restrictions on Assessment
and Collection of Deficiency in Tax and Acceptance of
Overassessment, that was executed by petitioner on October 18,
1991, and (4) petitioner's check to cover the excise tax under
section 4975(a) that, pursuant to that Form 870, was to be
imposed on petitioner as part of the 1991 settlement.
At the end of 1991, National Bank of Harrah and Harrah
Bancshares had a combined net operating loss carryforward of
$1,236,093. At the end of 1992, National Bank of Harrah was an
operating bank. On April 6, 1993, Harrah Bancshares, which owned
approximately 96 percent of the stock of National Bank of Harrah,
merged with Midwest Bancshares, and the common stock of Harrah
Bancshares was canceled. On April 16, 1993, National Bank of
Harrah merged with and into Midwest Bank, each share of Midwest
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