- 14 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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