- 6 - After the formation of Estes Homes, Mr. Shedd continued as manager of the Tucson Division of Estes Co. During September 1980, a decision was made to transfer key management personnel from Estes Co. to petitioner in order to provide certain fringe benefits to those individuals. In furtherance of that decision, petitioner and Estes Co. entered into a management contract on September 20, 1980, in which petitioner agreed to employ certain management employees of Estes Co., including Mr. Shedd, Mr. Estes, and Jon Grove (Mr. Grove), among others, and through them to provide management services to Estes Co. Mr. Estes was designated president of Estes Co., Mr. Shedd was designated its executive vice president, and Mr. Grove was designated it vice president--finance. The management contract was amended on January 5, 1981, to state specifically that the provision of management services by petitioner was not to be construed as creating a partnership between petitioner and Estes Co. Mr. Shedd served as executive vice president of Estes Co. until his retirement from that company during 1981. To effectuate his retirement, petitioner and WE 7 amended their partnership agreement to provide, in effect, for the buyout of petitioner's interest in Estes Co. Under the terms of the amended partnership agreement, dated January 5, 1981, WE 7 agreed to distribute petitioner's capital account over a 10-year period commencing August 31, 1981, as well as to pay interest on the outstanding balance at a rate of 9 percent until the capitalPage: 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