-9- ALSL. During the relevant years, the owners of Sun Valley Investments, a partnership, were Thomas and Stethem. Pursuant to ALSL’s operating agreement, ALSL’s members were required to contribute the following capital to ALSL: Member Contribution Edward Hubert $200 George Hubert, Jr. 200 Sharon Hubert 200 Ollinger 50 Stethem 50 Sun Valley Investments 100 Thomas 200 1000 None of ALSL’s members, with the exception of Thomas and Stethem, ever contributed any capital to ALSL from his, her, or its own funds. During 1996, Thomas and Stethem contributed $200,000 and $50,000, respectively, to ALSL’s capital.4 As of December 31, 1995, ALSL reported for Federal income tax purposes that it had cash of $7,298, that it owned a $1,338,334 nonrecourse note receivable from ALD, and that it was liable on a $1,345,684 nonrecourse note payable to HEI. ALSL 4 During HEI’s 1997 taxable year, Thomas was HEI’s most highly compensated officer, and Edward Hubert, George Hubert, Jr., and Sharon Hubert were its next three most highly compensated officers. During that year, HEI paid Thomas $420,922, and it paid $370,236 to each of the other three officers. During HEI’s 1998 taxable year, Thomas received significantly less compensation than these other three officers. During HEI’s 1998 taxable year, HEI paid Edward Hubert, George Hubert, Jr., Sharon Hubert, and Thomas $644,236, $894,236, $644,236, and $397,342, respectively.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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