Andantech L.L.C., Wells Fargo Equipment Finance, Inc. (f.k.a. Norwest Equipment Finance, Inc.), Tax Matters Partner, and Wells Fargo & Co., A Partner Other Than the Tax Matters Partner, et al. - Page 60




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          Comdisco, as settlor, and by Robert Kelman, as sole trustee.  The             
          beneficiaries of the Trust were various charitable organizations,             
          and the Trust was a tax-exempt organization.                                  
               C.   Transfer of Mr. Parmentier’s Membership Interest to RD              
               Leasing in Exchange for Preferred Stock (Appendix F)                     
               Mr. Parmentier transferred his 98-percent membership interest            
          in Andantech to RD Leasing pursuant to an Exchange Agreement dated            
          December 10, 1993.  RD Leasing issued 6,150 shares of series A                
          preferred stock (the RD Leasing preferred stock) to Mr. Parmentier            
          in exchange for his 98-percent membership interest.  Mr. Parmentier           
          thereafter withdrew as a member of Andantech, and RD Leasing was              
          admitted.                                                                     
               The RD Leasing preferred stock provided for a dividend at the            
          rate of 6.878 percent.  The 6,150 shares of RD Leasing preferred              
          stock issued to Mr. Parmentier had a liquidation preference of                
          $615,000 (plus unpaid dividends).  The 6,150 shares of preferred              
          stock had a value of 0.5 percent of the equipment’s purchase price            
          (approximately $122 million).                                                 
               Mr. Parmentier agreed to hold the RD Leasing preferred stock             
          for 1 year (i.e., through December 10, 1994).  RD Leasing, however,           
          was required to maintain a portion of its assets in “permitted                
          investments” (low-risk securities) sufficient to satisfy the                  
          liquidation preference, including all accrued but unpaid dividends.           
          RD Leasing had the option to redeem the RD Leasing preferred stock            
          on or after January 1, 2000, at a price equal to the liquidation              






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