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Article IV, entitled “Alimony”, required Mr. Hoffman to pay
decedent, as permanent alimony, the annual sum of $300,000,
payable bimonthly in equal installments of $12,500. The combined
amount of the bimonthly installments, $25,000, was referred to as
the “INITIAL BASE MONTHLY ALIMONY AMOUNT.” The payments
commenced on January 1, 1992, and only the death of decedent or
Mr. Hoffman would act to terminate the alimony due. The payments
to decedent were described as alimony for spousal support and
were intended by the parties to be taxable to decedent as income
and deductible by Mr. Hoffman for Federal income tax purposes.
Article VI, entitled “Equitable Division of Marital Estate”,
divided the existing marital property of decedent and Mr. Hoffman
and was intended to settle all issues regarding the marital
property. In addition to other obligations, Mr. Hoffman was
required to convey to decedent: (1) One-half of his 55-percent
interest in Clubside Partnership (Clubside); (2) 100 percent of
the stock of Hoffman Associates, Inc. (Hoffman Associates), and a
loan receivable from Hoffman Associates; (3) 770 shares of stock
in Walden Lake, Inc. (WLI); and (4) 560 shares of stock in Sun
City Center, Inc. (SCC).
Paragraph 6.6B of article VI provided for distributions to
decedent from WLI and SCC. In the event that WLI and SCC did not
make the distributions by certain dates, Mr. Hoffman personally
guaranteed payment of specific amounts to decedent on or before
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