Coggin Automotive Corporation - Page 14

                                       - 14 -                                         
          Inc. note to CA Motors, Ltd., in exchange for a 20-percent limited          
          partnership interest, and (3) Mr. Caracello contributed the                 
          $222,133 Coggin-O’Steen Motors, Inc. note to CFP Motors, Ltd., in           
          exchange for a 5-percent limited partnership interest.  By                  
          September 30, 1993, the aforementioned notes were canceled.                 
               Each partnership agreement provided that the general partner,          
          i.e., one of the newly formed S corporations, would have control            
          over the operations of the partnership.  Further, each partnership          
          agreement provided that the general manager/limited partner had to          
          tender his partnership interest to the partnership in the event he          
               Immediately following the transfers of assets to the                   
          partnerships, the subsidiaries were liquidated.  As a result,               
          petitioner obtained the subsidiaries’ limited partnership                   
               On or about August 27, 1993, petitioner elected S corporation          
          status, effective June 27, 1993.  At the time of the election, no           
          changes were made to petitioner’s capital structure or to the               
          ownership interests in its stock.                                           
          Subsequent Transactions                                                     
               On November 1, 1993, Mr. Hanania acquired an additional 20-            
          percent limited partnership interest in CA Motors, Ltd., for                
          $179,707.  Subsequently, he purchased another 10-percent limited            
          partnership interest for $101,103.  Ultimately, on July 1, 1996,            

Page:  Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  Next

Last modified: May 25, 2011