Ina F. Knight - Page 7




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          management trust satisfied all requirements under Texas law to                
          create a trust.  The management trust was the partnership’s                   
          general partner.                                                              
               d.   Petitioners each transferred a one-half unit of the                 
          partnership to the management trust.  That unit is the only asset             
          held by the management trust.  Petitioners each owned a 49.5-                 
          percent interest in the partnership as limited partners.                      
               e.   Petitioners created trusts for Mary Knight and Douglas              
          Knight (the children’s trusts).  The documents petitioners                    
          executed were sufficient under Texas law to create the children’s             
          trusts.  Douglas Knight and Mary Knight were each the beneficiary             
          and trustee of the children’s trust bearing their name.                       
               f.   Petitioners each signed codicils to their wills in                  
          which they changed the bequests to their children to bequests to              
          the children’s trusts.                                                        
               g.   Petitioners each transferred a 22.3-percent interest in             
          the partnership to each of the children’s trusts.  After those                
          transfers, petitioners each retained a 4.9-percent interest in                
          the partnership as limited partners.                                          
               3.   The Partnership Agreement                                           
               The partnership has been a limited partnership under Texas               
          law since it was created.  Article 9 of the partnership agreement             
          prohibits any partner from withdrawing from the partnership or                
          demanding the return of any of his or her capital contribution or             






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Last modified: May 25, 2011