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dividend or capital gains tax. One year later in 1987, Mr. Page
led an in-depth discussion regarding Lincoln's current and future
operations at Lincoln's annual board meeting.
In February 1988, during Lincoln's board meeting, Mr. Page
moved that Lincoln buy 10-year term interests for up to
$6 million. He also moved to have Lincoln redeem $5,440,000
worth of its preferred stock no later than March 31, 1988. An
addendum to Mr. Page's first letter followed in March 1988. Then
on March 28, 1988, Lincoln redeemed its preferred stock, and 3
days later, on March 31, 1988, Lincoln and the Lincoln Family
Trusts formed four of the nine Lincoln Partnerships.
In April 1988, Mr. Page prepared yet another letter fleshing
out the transactional details of his plan. Approximately 3
months later in July 1988, CGF made distributions to its
shareholders and formed five limited partnerships with the CGF
Family Trusts. Then in early October 1988, at one of Lincoln's
board meetings, Mr. Page moved that Lincoln purchase term
interests in up to five additional partnerships. He also moved
to have Lincoln declare another dividend. The dividend distribu-
tion took place on October 31 and approximately 1 month later on
December 9, 1988, Lincoln and the Lincoln Family Trusts created
five more partnerships.
This chronology of events shows a definite pattern. Each
time petitioners formed partnerships and acquired term interests
therein, distributions were paid so that their shareholders
could, likewise, invest in such partnerships and acquire the
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