- 11 - with the exception of clothing, jewelry, furniture, and furnishings previously divided. Of the 5,000 shares of Ameritech stock held in petitioner Praegitzer's name, one-half were allocated to petitioner Dawes as her separate property, and one- half were allocated to petitioner Praegitzer as his separate property. In the MSA, the parties expressed their intention that the MSA “be subject to the rules of IRC Section 1041, where applicable.” The MSA further provided that “The Parties have made the transfers set forth in this paragraph with the intent that such transfers constitute equitable division of their community and jointly-owned property.” In the MSA, the parties intended that the agreement be a final and complete settlement of all rights and obligations between them, including property rights and property claims and the right of either petitioner Dawes or petitioner Praegitzer to spousal support. The reorganization agreement was executed by Ameritech, petitioner Praegitzer, petitioner Dawes, and Kerry Dawes. The reorganization agreement provided that the 303 products business would be placed in a new corporation to be owned solely by petitioner Praegitzer and that the propeller business would remain in Ameritech which would be owned solely by petitioner Dawes and Kerry Dawes. The reorganization agreement provided that Ameritech would cause the formation of a new subsidiary known as 303 Products, Inc. (303 Products), with an initial stock issue of 1,000 shares of common stock, to which Ameritech wouldPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011