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the remaining 99.9 percent to partnership interest B. The
Lincoln Partnerships, like their CGF counterparts, were also
required to make annual distributions of income, pursuant to the
Kansas Uniform Principal and Income Act, and in accordance with
the partners' interests in the partnerships.
Simultaneously with the execution of the Lincoln partnership
agreements, Lincoln and the Lincoln Family Trusts executed
separate agreements for each partnership detailing how
partnership interest B would be owned. Four of the nine
agreements stated that Lincoln would own partnership interest B
during the first 10 years of forming the partnership, after which
partnership interest B would become the sole property of the
Lincoln Family Trusts. The remaining five agreements stated that
Lincoln would own partnership interest B for a term of 20 years
from the date of its capital contribution, after which the
Lincoln Family Trusts would become sole owners of the interest.
During the period of the Lincoln term interests, Lincoln would be
entitled to all of partnership interest B's share of partnership
distributions.
Lincoln and the Lincoln Family Trusts made the following
cash contributions to the Lincoln Partnerships in exchange for
their respective term and remainder interests in partnership
interest B:
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