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the CGF Partnerships and their respective contribution amounts is
attached to this opinion as appendix A.
The CGF partnership agreements provided that each part-
nership's net profits and losses were to be borne by the partners
in the same percentage as their capital contributions; namely, .1
percent by the holder of partnership interest A and the remaining
99.9 percent by partnership interest B. The CGF partnership
agreements also required each partnership to make annual distri-
butions of income, pursuant to the Kansas Uniform Principal and
Income Act, and in accordance with the partners' interests in the
partnership.
Simultaneously with the execution of the CGF partnership
agreements, CGF and the CGF Family Trusts executed separate
agreements wherein they set down exactly how partnership interest
B would be owned. They agreed that CGF would be the owner of a
10-year term interest in partnership interest B, upon the
expiration of which it would become the sole property of the CGF
Family Trusts. During the period of its term interest, CGF was
entitled to all of the partnership income allocable to
partnership interest B, and, upon the expiration of the term
interest, the corporation was entitled to all accrued but unpaid
income.
CGF and the CGF Family Trusts contributed cash to the CGF
Partnerships in the following amounts in exchange for their
respective term and remainder interests in partnership interest
B:
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Last modified: May 25, 2011