Ina F. Knight - Page 9




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          checking account.  The partnership paid the management trust                  
          expenses, such as preparation of the trust tax returns.                       
               2.   Operation of the Partnership                                        
               Petitioner signed all of the checks drawn on the partnership             
          checking account.  The partnership kept no records, prepared no               
          annual reports, and had no employees.  The children and their                 
          trusts did not participate in managing the partnership.  The                  
          partners or their representatives have not exchanged any                      
          correspondence, meeting notes, or e-mail about the partnership’s              
          operations.  The partners never met and never discussed                       
          conducting any business activity.  All assets and know-how came               
          from petitioners.                                                             
               The partnership has never borrowed or lent money, and never              
          conducted any business activity.  It has not bought, otherwise                
          acquired, or sold any notes or obligations of any entity other                
          than Government-backed securities.  The partnership did not                   
          prepare annual financial statements or reports.                               
               3.   Partnership Assets                                                  
               Petitioner did not trade the partnership’s bond funds.  He               
          reinvested the partnership’s Treasury notes when they matured.                
          He managed these investments the same way before and after he                 
          transferred them to the trust.  The partnership did not rent real             
          property to third parties.                                                    








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Last modified: May 25, 2011