Ina F. Knight - Page 8




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          the balance in that partner’s capital account.  Article 14                    
          provides that the partnership will continue for 50 years, unless              
          all partners consent to a dissolution.  Under the partnership                 
          agreement, petitioner, as trustee of the management trust, could              
          sell any asset or part of any asset at any time.                              
               The fair market values (before any discounts) of partnership             
          assets on December 28, 1994, were as follows:                                 
               Freestone County Ranch (with mineral rights)     $182,251                
               Residential property (6219 Dilbeck)                 166,880              
               Residential property (14827 Chancey)               145,070              
               USAA municipal bond fund                           553,653              
               Dreyfus municipal bond fund                        510,239              
               Treasury notes                                     461,345              
               Insurance policies                                 51,885               
               Cash                                              10,000                 
                    Total                                     2,081,323                 
               Petitioners transferred the bond funds and Treasury notes to             
          brokerage accounts in the name of the partnership.  The                       
          partnership had no liabilities and no assets other than those                 
          listed above.  All of these assets were petitioners’ community                
          property before being transferred to the partnership.                         
          C.   Operation of the Management Trust and Partnership                        
               1.   Operation of the Management Trust                                   
               Petitioner has been the only trustee of the management                   
          trust.  Petitioner decides which assets to buy and sell, pays all             
          partnership expenses, handles and keeps records of all                        
          partnership transactions, and explains the transactions to the                
          partnership's accountants.  The management trust has never had a              






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