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On May 25, 1990, pursuant to a recapitalization
of the stock of the Hugo Bosca Company, Inc.,
the Donor exchanged his 402.5 shares of voting
common stock of the Hugo Bosca Company, Inc.,
for 402.5 shares of a newly created class of non-
voting common stock of the Hugo Bosca Company,
Inc. The non-voting common shares provided the
same rights as the voting common shares given up
except for the voting rights. The ownership of
the shares of stock immediately before and
immediately after the recapitalization was as
follows:
PRE-RECAP POST-RECAP
Relationship Voting Voting Nonvoting
to Donor Common Common Common
Mario Bosca Donor 402.5 -- 402.5
Marie Bosca Wife 292.5 -- [1]292.5
Christopher Bosca Son 55.0 55.0 --
Anthony Bosca Son 55.0 55.0 --
Under the facts and circumstances of the
recapitalization, it is the Donor's position that
the recapitalization did not result in a gift by
the Donor.
[1This schedule does not reflect Ms. Baker's
transfer of her HBC stock to the decedent.]
Ms. Baker also filed Form 706, United States Estate
(and Generation-Skipping Transfer) Tax Return, on behalf of
the decedent's estate. The return reports a total gross
estate of $9,604,543.03 and total allowable deductions of
$9,008,628.03 for a taxable estate of $595,915. It also
reports adjusted taxable gifts of $527,217 for a total of
$1,123,132 subject to tentative tax. The adjusted taxable
gifts reported on the decedent's estate tax return,
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