MARK W. SENDA AND MICHELE SENDA - Page 7

                                        - 7 -                                         

                           Partner                  Percentage    Interest            
          Mark W. Senda, Trustee, or his            1.0           General             
          successors in trust, under the Mark W.                                      
          Senda Revocable Trust dated Feb. 23,                                        
          1998, and any amendments thereto                                            
          Mark W. Senda, Trustee, or his            97.97         Limited             
          successors in trust, under the Mark W.                                      
          Senda Revocable Trust dated Feb. 23,                                        
          1998, and any amendments thereto                                            
          Michele Senda                             1.0           Limited             
          Citicorp Trust South Dakota and Robert    0.01         Limited              
          Brendell, Trustees of the                                                   
          Mark R. Senda Irrevocable Trust                                             
          Citicorp Trust South Dakota and Robert    0.01         Limited              
          Brendell, Trustees of the                                                   
          Ross J. Senda Irrevocable Trust                                             
          Citicorp Trust South Dakota and Robert    0.01         Limited              
          Brendell, Trustees of the Janell N.                                         
          Senda Irrevocable Trust                                                     
               On December 20, 1999, petitioners contributed to SFLP II               
          18,477 shares of stock in exchange for their partnership                    
          interests.  Petitioners transferred the stock from their joint              
          brokerage account to the brokerage account of SFLP II.  Both                
          accounts were held at Salomon Smith Barney.  Trusts for the                 
          children purportedly contributed oral accounts receivable in                
          exchange for their partnership interests.  The accounts                     
          receivable, however, were never reduced to writing, had no terms            
          for repayment, and had not been paid as of the time of trial.  On           
          that same day, petitioner gave to each child, in trust, a                   
          17.9-percent limited partnership interest in SFLP II.  The                  







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011