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Frederick Underwriters.4 From at least 1986 through 1997, Mr.
Ramsburg made cash capital contributions to Kildare Timmy total-
ing approximately $1,336,459. The total amount of Mr. Ramsburg’s
cash capital contributions included $283,500 that, as found
below, he borrowed from Frederick Underwriters and contributed to
Kildare Timmy. On January 1, 1998, the date on which Kildare
Timmy distributed all of its assets to Mr. Ramsburg (discussed
below), Mr. Stottlemeyer did not own a 50-percent capital inter-
est in Kildare Timmy.
On November 1, 1992, Frederick Underwriters made two loans
in the amounts of $140,000 and $143,500, respectively, to Mr.
Ramsburg in his individual capacity and not in his capacity as a
general partner of Kildare Timmy (collectively, Frederick Under-
writers’ 1992 loans to Mr. Ramsburg). On that date, Mr. Ramsburg
signed in his individual capacity and not in his capacity as a
general partner of Kildare Timmy two promissory notes payable to
Frederick Underwriters in the amounts of $140,000 and $143,500,
respectively, that evidenced such respective loans. (We shall
refer collectively to that $140,000 promissory note and that
$143,500 promissory note as Mr. Ramsburg’s 1992 notes.) Each of
Mr. Ramsburg’s 1992 notes provided for interest at the annual
4In order to make cash capital contributions to Kildare
Timmy, Mr. Stottlemeyer directed Frederick Underwriters to
transfer on his behalf certain amounts of his salary to Kildare
Timmy.
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