- 41 - regulations in place do not support a conclusion that the disputed provisions in the KFLP and KILP partnership agreements constitute applicable restrictions. Conclusion In sum, we hold that petitioners transferred limited partnership interests to the GRAT’s trustees. However, consistent with the preceding discussion, we conclude that section 10.01 of the partnership agreements does not contain “an applicable restriction” within the meaning of section 2704(b). Accordingly, we will grant petitioners' motion for partial summary judgment as it pertains to this issue. To reflect the foregoing, An order granting petitioners’ Motion for Partial Summary Judgment will be issued as it relates to the section 2704(b) issue.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41
Last modified: May 25, 2011