- 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.
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