- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011