- 9 - Mr. Martin presented a request for the approval to change the borrower on the $1.1 million in loans to Salem, Saxon & Nielsen, P.A. to the names of Richard J. Salem, Bernice S. Saxon, and Richard A. Nielsen based on their pro-rata share ownership of the firm. * * * Mr. Martin indicated that as a result of an IRS audit the firm is undergoing, the partners are being questioned regarding the basis of their individual ownerships in the corporation. He mentioned that the P.A. will hypothecate its assets as collateral for the notes to the partners. He indicated that we will continue to have a $700M assignment of life insurance on Mr. Salem. He mentioned that Mr. Salem owns 85%, Ms. Saxon owns 10%, and Mr. Nielsen owns 5% of the firm. * * * C. Gulf Properties of Pinellas County, Florida III, Inc. Mr. Salem owned a one-third interest in an S corporation known as Gulf Properties of Pinellas County, Florida III, Inc. (Gulf Properties). On June 30, 1988, Gulf Properties purchased property located at 300 Gulf Boulevard, Belleair Shores, Florida (300 Gulf Boulevard), for the purchase price of $600,000. On December 28, 1990, Gulf Properties transferred title of 300 Gulf Boulevard to Mr. Salem, subject to a mortgage in the amount of $530,900. Between 1987 and 1992, real property values dropped significantly in the area of 300 Gulf Boulevard. D. Petitioners' Income Tax Returns The Salems filed a joint income tax return (Form 1040) and an amended return (Form 1040X) for the taxable year 1990. The Salems reported a net operating loss for 1990 in the amount of $192,546. In computing the 1990 net operating loss, the Salems included the $221,140 loss from SS&N. The Salems did not reportPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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