Dennis A. and Tai K. Praegitzer - Page 11

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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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Last modified: May 25, 2011