Reginald Maurice Wise and Shannon Rae Wise - Page 6

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               3.   Intent Corporation                                                 
               Intent, an S corporation on the accrual basis with a fiscal             
          year ending March 31, was formed in 1972.  During fiscal years               
          1988 and 1989, Wise held 31.25 percent and Eicher held 68.75                 
          percent of Intent's income, credits, and deductions.                         
               4.   WRI Corporation                                                    
               WRI, an S corporation on the accrual basis with a fiscal                
          year ending July 31, was formed in 1973.  Wise was president of              
          WRI at all times relevant here.  WRI initially engaged in real               
          estate brokerage activities, but was essentially inactive from               
          1978 to 1985.  WRI owned and operated a resort near Kissimmee,               
          Florida, during its fiscal year 1988.  Wise and Eicher each were             
          entitled to 50 percent of WRI's income, credits, and deductions              
          during WRI's fiscal years 1988 and 1989.                                     
          C.   Mortgages and Loans                                                     
               1.   The Hersco Mortgage and HMC's Loan to WRI                          
                    a.   WRI's Purchase of Land From Hersco                            
               Hersco owned 35 acres of unimproved land in Osceola County,             
          Florida, which it bought for about $134,000 in 1973.  In 1984, an            
          independent appraiser valued the land at $1,468,000.  On August              
          14, 1984, Hersco sold the land to WRI for $1,468,000.  At the                
          closing, WRI paid Hersco $88,000 in cash and gave Hersco a                   
          $1,380,000 mortgage on the land (the Hersco mortgage).  Hersco               
          sold the land to WRI so Wise and Eicher could develop it in                  
          corporate form and thereby limit their personal liability.                   




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