- 4 - Tharp--14.5 percent, Charles Tharp--29 percent, Claudia Keith--9 percent, Claud Tharp--33 percent, and the Estate of Glenda Tharp--14.5 percent; (3) capital and profit interests in the Tharp Family Partnership were owned, as follows: William Tharp-- 10 percent, Charles Tharp--10 percent, Claudia Keith--10 percent, and each child of William, Charles, and Claudia owned a 10- percent interest, accounting for the remaining 70 percent; (4) capital and profit interests in the Tharp Farms Partnership were owned as follows: William Tharp--30 percent, Charles Tharp--30 percent, Claudia Keith--20 percent, Claud Tharp--20 percent; and (5) capital and profit interests in the Tharp Enterprises Partnership were owned as follows: William Tharp--25 percent, Charles Tharp--25 percent, Claudia Keith--25 percent, and Claud Tharp--25 percent. The various interests of petitioner’s shareholders and of other family members in the entities to which indirect loans were made are reflected in a chart attached to this opinion as an appendix. The following interest-free loans were made by petitioner directly to shareholders: Demand Note Borrower Dated Amount Charles Tharp Aug. 31, 1994 $29,978.74 William Tharp Aug. 31, 1994 11,100.00 William Tharp Aug. 31, 1994 28,113.21 Respondent’s agent computed interest at the applicable Federal rate on the loans directly to shareholders in the aggregatePage: 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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