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agreements, the term of the first four partnerships created was
limited to 20 years, and the term of the last five partnerships
created was 30 years.
Lincoln's shareholder-family trusts contributed cash to the
Lincoln Partnerships in exchange for partnership interest A.
Lincoln, in its own right, contributed cash in exchange for 10-
year term interests in four Lincoln Partnerships and 20-year term
interests in the remaining five Lincoln Partnerships (collec-
tively referred to as the Lincoln term interests). Lincoln's
term interests were, in all cases, designated term interests in
partnership interest B. Lincoln's shareholder-family trusts or,
in one instance, a limited partnership related to the former
contributed cash for the remainder interests in partnership
interest B. For convenience, all the remaindermen in the Lincoln
Partnerships are sometimes collectively referred to as the
Lincoln Family Trusts. The list of entities making up the
Lincoln Partnerships and their respective contribution amounts is
attached to this opinion as appendix B.
The Lincoln partnership agreements required the partners to
bear their respective partnerships' net profits and losses in the
same percentage as their capital contributions. Thus, six of the
Lincoln partnership agreements allocated 1 percent of net profits
and losses to the holder of partnership interest A and the
remaining 99 percent to partnership interest B, while the other
three Lincoln partnership agreements, like the CGF partnership
agreements, allocated .1 percent to partnership interest A and
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