Baine P. and Mildred C. Kerr - Page 14




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          December 30, 1995, the GRAT’s transferred demand notes to                   
          petitioners as required under the assignments described above.  The         
          original principal amounts due on the December 30, 1995, GRAT’s             
          demand notes held by petitioners Baine P. Kerr and Mildred C. Kerr          
          were $795,148.76 and $795,716.99, respectively.                             
               On December 29, 1994, petitioners (in their individual                 
          capacities and as GRAT’s trustees) executed documents entitled              
          “Security Agreement-Assignment of Partnership Interest” under which         
          the GRAT’s assigned to petitioners, as security for the GRAT’s              
          demand notes, the GRAT’s class B limited partnership interests in           
          KFLP.                                                                       
               During 1995, petitioners received interest payments on the             
          GRAT’s demand notes totaling $18,792.47.  The GRAT’s were                   
          terminated on December 30, 1995, and the remaining assets and               
          liabilities of the GRAT’s were transferred to the Kerr Issue GST            
          Trusts.                                                                     
               By separate agreements dated February 28, 1998, petitioners            
          agreed that the remaining principal and interest payments due on            
          the December 30, 1995, GRAT’s demand notes--then the liabilities of         
          the various Kerr Issue GST Trusts--would be forgiven subject to the         
          condition that the trustees agree to pay any Federal and State              
          gift, estate, inheritance, transfer, succession, and generation-            
          skipping transfer tax associated with the transfer.                         








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