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interest.19 The funds to make the contributions came from
decedent.
On February 25, 1997, decedent signed a $1,000 check made
payable to TCO, which was delivered to TCO with instructions to
treat the payment as a $500 contribution to GFLP on behalf of
each of the Pamela Powell and Michael Gore Trusts. On February
27, 1997, in response to decedent’s request, TCO issued two $500
checks, representing the initial capital contributions by the
Pamela Powell and Michael Gore Trusts for their 1-percent limited
partnership interests, to GFLP.
On February 25, 1997, Ms. Powell opened a checking account
for GFLP, account No. xx-xxxx-xx7045 (GFLP account No. 7045),
with an initial deposit of $24,168.10.20 On March 3, 1997, Ms.
Powell deposited $2,000, representing the capital contributions
of Ms. Powell, Mr. Gore, the Pamela Powell Trust, and the Michael
Gore Trust, into GFLP account No. 7045. Additional deposits of
$226,456.76 were made to GFLP account No. 7045 between February
25 and March 7, 1997.21
19The terms of the partnership agreement had required Ms.
Powell and Mr. Gore to pay such amounts when they executed the
partnership agreement on Dec. 26, 1996.
20This was the only GFLP bank account in existence during
decedent’s life.
21Ms. Bowers testified that decedent deposited a portion of
the distributions from Sidney Gore’s individual retirement
accounts, on which decedent was a designated beneficiary, into
(continued...)
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