-10- reported no other asset or liability as of that date, but for a $52 bank charge which it elected to amortize over 60 months. As of December 31, 1996, ALSL reported for Federal income tax purposes that its sole asset was cash of $7,298 and that it had no liabilities. ALSL also reported for Federal income tax purposes that it had realized a $250,000 loss for 1996. ALSL reported that the loss was attributable to “Defeasance of Debt Income”, “Bad Debt Losses”, and “Miscellaneous Expenses” of $2,345,685, negative $2,588,376, and negative $7,309, respectively. As of December 31, 1997, ALSL reported for Federal income tax purposes that it had no assets, liabilities, or capital. V. ALSL Note Pursuant to a promissory note (ALSL note) dated January 18, 1995, ALSL (under the name Seasons of Sarasota Limited Liability Co.) promised to pay HEI “$2,500,000.00, or so much thereof as may be advanced and outstanding pursuant to any advances made by the Lender to the Company.” The ALSL note was drafted as a demand note without a fixed maturity date, and it stated that it bore interest at a rate corresponding to the applicable Federal rate. In connection with the ALSL note, HEI transferred a total of $2,440,684.38 to ALSL from January 18, 1995, through March 6, 1997. ALSL then transferred those funds to ALD in connection with a January 18, 1995, nonrecourse promissory note (ALD note)Page: 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