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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 would
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