- 5 - Ampel notes, with $201,158.56 to be paid immediately, in cash, and the balance ($19.3 million) due on March 2, 1999. Floridama’s obligation to pay $19.3 million on March 2, 1999, was evidenced by its interest-bearing note (the Floridama note). Interest was to be paid on the Floridama note at an annual rate of 10.88 percent. Pursuant to a stock pledge agreement, petitioner held Floridama stock as security for the Floridama note. On March 2, 1989, the accrued interest on the 1987 Ampel notes was $2,449,974. Petitioner’s adjusted basis in the 1987 Ampel notes at their sale to Floridama was $6,940,865 Sometime in 1991, petitioner exchanged the Floridama note for two notes from Ampel in the total amount of $25.5 million (the 1991 Ampel notes). Petitioner exchanged the Floridama note for the 1991 Ampel notes in order to facilitate Ampel’s redemption of the 1987 Ampel notes. He did so because Ampel had failed to pay interest to Floridama on the 1987 Ampel notes, and Floridama had threatened to foreclose on the related mortgages, which, petitioner believed, would have limited the amount that, eventually, he would have been able to obtain from Floridama with respect to the Floridama note. As of the time of trial, petitioner still held the 1991 Ampel notes, on which he had, as of then, received no payment. Holland Spring Notes Holland Spring, Inc. (Holland Spring) is a Florida corporation. In December 1987, Holland Spring purchased fromPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011