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year thereafter. The proceeds of the loan were distributed in
the form of a check (#2512) from HL to Dart drawn on HL’s account
with Havre.
In 1995, a similar problem arose with HS. HS purchased
tractors and the accelerated depreciation deductions from those
tractors were anticipated to exceed Mr. Oren’s basis in HS. Mr.
Oren restructured his investments to increase his basis in HS.
On December 8, 1995, Dart lent $1.9 million to Mr. Oren.
Mr. Oren executed a note which provided that principal was due
375 days following demand. Interest accrued at a 7-percent
annual rate and was due on December 8, 1996, and on the same day
of each year thereafter. The proceeds of the loan were
distributed in the form of a check (#168445) from Dart to Mr.
Oren drawn on Dart’s account with Havre.
On December 21, 1995, Mr. Oren lent $2 million to HS. HS
executed a note which provided that principal was due 375 days
following demand. Interest accrued at a 7-percent annual rate
and was due on December 21, 1996, and on the same day of each
year thereafter. The proceeds of the loan were distributed in
the form of a check (#3088) from Mr. Oren to HS drawn on Mr.
Oren’s Fidelity account.
On December 21, 1995, HS lent $2 million to Dart. Dart
executed a note which provided that principal was due 375 days
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Last modified: May 25, 2011