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were filed, Mable, Gary, and Cynthia Bean resided in Amity,
Arkansas.
Shortly after decedent’s death, Gary Bean was appointed
administrator of decedent’s estate.
For convenience, hereinafter all references to petitioners
refer to decedent and Mable Bean and to Gary and Cynthia Bean.
For many years, decedent and Gary Bean jointly owned and
managed a trucking business in Amity, Arkansas. Through 1992,
decedent and Gary Bean operated the trucking business as a
partnership (the Partnership). During all relevant periods,
decedent owned a 75-percent interest in the Partnership, and Gary
Bean owned a 25-percent interest in the Partnership.
On April 30, 1988, decedent, Mable, and Gary Bean formed an
Arkansas corporation (the Corporation) that elected in 1989 to be
taxed pursuant to subchapter S of the Internal Revenue Code.
From early 1988 through 1992, decedent and Mable Bean owned 75
percent of the stock in the Corporation, and Gary Bean owned the
remaining 25 percent of the stock in the Corporation.
Through 1992, the Corporation, through its employees,
provided maintenance on and parts for the trucks of the
Partnership.
On October 9, 1990, decedent and Mable Bean executed a
$960,019 second mortgage on their personal residence to the Bank
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Last modified: May 25, 2011