-13-
interest was never paid. HEI never accrued any other interest on
the HEI note.
The $43,418.06 payment that ALSL made to HEI on July 14,
1997, resulted from a reported liquidation of ALD’s assets in
1996.
VI. ALD
ALD was a Florida limited partnership formed on January 6,
1995, to develop the Seasons of Sarasota. ALD had one general
partner, ALSL, and one limited partner, James Culpepper
(Culpepper). Thomas was an ALD officer.
Pursuant to the ALD limited partnership agreement, ALSL was
to acquire a 97-percent interest in ALD in exchange for a $100
capital contribution, and Culpepper was to acquire a 3-percent
interest in ALD in exchange for a $100,000 capital contribution.
The limited partnership agreement stated that the percentages of
the partners’ interests in ALD did not have any relationship to
their respective capital contributions. Culpepper contributed
the referenced $100,000 in 1995. ALSL never contributed the
referenced $100 as such.
For its taxable years ended December 31, 1995, 1996, and
1997, ALD filed Federal partnership returns of income. ALD
reported and had no revenue for those years.
As of December 31, 1995, ALD reported on its 1995 return
that it had assets totaling $1,438,334 and a single liability of
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