Estate of Marcia P. Hoffman, deceased, Elisabeth Hoffman, Personal Representative - Page 7




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               ALIMONY AMOUNT shall be deemed taxable to the Wife and                 
               deductible by the Husband for federal income tax                       
               purposes, it is the intent of the parties that all                     
               amounts received by the Wife pursuant to Paragraph                     
               6.6(B), although they may operate to ultimately reduce                 
               the alimony amount payable by the Husband, shall not be                
               deemed taxable to the Wife as income nor deductible by                 
               the Husband for federal income tax purposes.  It is                    
               intended by the parties that the * * * [guaranteed                     
               payment under paragraph 6.6B for $300,000 due on or                    
               before December 31, 1998], upon being paid, will create                
               a principal sum for the Wife which, if invested at the                 
               rate of eight percent (8%), will create sufficient                     
               income to reduce her need for permanent alimony                        
               contemplated by this Agreement, based upon the                         
               aforementioned terms.                                                  
               Paragraph 6.6E contained another offset provision.  This               
          provision related to compensation received by Mr. Hoffman for his           
          performance of all services related to SCC and WLI or other                 
          investments.  Paragraph 6.6E provided that decedent was to                  
          receive 35 percent of any and all posttax amounts received by Mr.           
          Hoffman as direct or indirect compensation in connection with his           
          employment, to the extent that such compensation amounts exceeded           
          $600,000 for any 1 calendar year.  To the extent decedent                   
          received any payments pursuant to this provision, the amounts               
          received would constitute partial satisfaction of Mr. Hoffman’s             
          guaranty obligation under paragraph 6.6B.  At such time as Mr.              
          Hoffman paid all the amounts as required under paragraph 6.6B,              
          the obligation that Mr. Hoffman pay decedent the excess                     
          compensation over $600,000 annually would terminate.                        









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