- 7 - parties) certain patents, intangibles, and other stock interests in other business entities owned by ADCS were retained by ADCS; 6. Holdings LLC and Operating LLC then both contributed to ADCS-Limited the operating assets they had received from ADCS in exchange, respectively, for the receipt of a 99-percent limited partnership interest and a 1-percent general partnership interest in ADCS-Limited. After the above six steps in the reorganization of ADCS were implemented, ADCS filed with respondent an election for subchapter S status, effective April 1, 1996. In June of 1996, petitioner was formed as a Nevada corporation. Upon its formation, petitioner filed with respondent an election for subchapter S status, effective June 13, 1996. On July 9, 1996, ADCS was merged into petitioner. In 1996, the initial shareholders in petitioner and their respective ownership interests in petitioner were as set forth below: Percentage Name Interest Stephen H. Siegele 68.4 Frederick H. Siegele 11.5 Bernard McKeown 11.5 Stuart F. Siegele 3.8 Frederick J. Siegele 3.3 Robert Jackson 1.6 Before ADCS’ merger into petitioner, the shareholders in ADCS and their respective ownership interests in ADCS were identical to petitioner’s initial shareholders as set forthPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011