Estate of Fred O. Godley, Deceased, Fred D. Godley, Administrator CTA - Page 7




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          this purpose was required by HUD.  As of the valuation date, GMA              
          held no real estate or other fixed assets and served only as a                
          management company for the housing partnerships to oversee                    
          leasing, maintenance, and repair in compliance with HUD                       
          requirements.  GMA received a management fee from each of the                 
          housing partnerships equal to 10 percent of rental income.                    
               On the Federal estate tax return, decedent’s interests in                
          the five partnerships were reported at a fair market value of                 
          $10,000 each.  At the time of decedent’s death, the partnership               
          agreement for each housing project contained a provision granting             
          Fred Jr., or his personal representatives, heirs or assigns, the              
          option to purchase decedent’s interest in said partnership for                
          the sum of $10,000.1  This option provision was contained in each             
          of the original partnership agreements.  On December 31, 1990,                
          Fred Jr. exercised these options to purchase decedent’s interests             
          in the four housing partnerships for the payment of the option                
          price of $10,000 for each partnership interest, or $40,000.  On               

               1  Sec. 5.02 of each partnership agreement provides:                     
                         Notwithstanding any of the foregoing,                          
                    Fred D. Godley, or his personal                                     
                    representative, heirs or assigns, shall have                        
                    the option to purchase the Partnership                              
                    interest of F.O. Godley from either F.O.                            
                    Godley or his personal representative, heirs                        
                    or assigns, for the sum of Ten Thousand                             
                    $10,000.  This option may be exercised at any                       
                    time during the existence of the Partnership.                       
                    Fred D. Godley shall notify all other                               
                    Partners in writing of his intention to                             
                    exercise this option to purchase.                                   




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Last modified: May 25, 2011