- 6 - 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.Page: 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