-19-
latter part of 1996, some individuals who had reserved
condominium units canceled their reservations, and the number of
cancellations exceeded the number of new reservations. By
December 31, 1996, ALD had not sold 45 of the condominium units
planned for the first phase.
ALD never purchased the land from Schwartz, and the
construction of the Seasons of Sarasota never began. Nor did
Provident ever lend any funds to ALD, ALSL, or HEI. On
December 31, 1996, the duties and responsibilities of SMC ended
when SMC and ALD agreed to terminate their agreement because the
land had not been purchased.
IX. LCL
LCL is a Wyoming limited liability company formed on
April 30, 1998. LCL filed its initial Federal partnership return
of income on the basis of a taxable year ended July 31, 1998
(LCL’s 1998 taxable year). LCL’s organizers were Thomas, in his
capacity as managing member of Hubert Commerce Center, Inc.
(HCC), and Ollinger, in his capacity as vice president of HBW.
HCC was connected with both the HEI and HHC affiliated groups.
LCL’s ownership consisted of 100 membership units. During
LCL’s 1998 taxable year, HBW received 99 of those units in
exchange for a $9,900 capital contribution, and HCC received the
last unit in exchange for a $100 capital contribution. On
April 30, 1998, HBW and LCL also executed as a contribution to
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011