Estate of Suzanne W. Cullison, Deceased, J. Greg Cullison, Personal Representative - Page 11

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          grandchildren.  The annuity agreement further provided that the             
          land decedent transferred would not be security for the annuity             
          payments due from the grandchildren to decedent.  The agreement             
          also provided that each grandchild's undivided one-fourth                   
          interest in the four parcels was to be that grandchild's sole and           
          separate property.                                                          
               On August 29, 1989, decedent by warranty deed conveyed to              
          each of her grandchildren an undivided one-fourth interest in the           
          four parcels.  The warranty deed was executed by decedent on                
          August 29, 1989, and was recorded by the grandchildren on                   
          September 8, 1989.                                                          
               Decedent's four grandchildren entered into their Cullison              
          Enterprises partnership agreement (partnership agreement) on                
          August 29, 1989.  The partnership agreement provided that the               
          partnership would commence on August 29, 1989.  The partnership's           
          stated purpose was to own, manage, or perform work on any farms             
          or agricultural lands.  The partnership agreement restricted the            
          partners' ability to sell their interests in the partnership to             
          third parties.  In addition, upon the partnership's liquidation,            
          any partner would have the right to bid on the partnership's                
          assets, and the bid would have to be accepted unless an                     
          outsider's bid on the assets was at least 20 percent higher.                








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