Estate of Robert V. Schuler - Page 9




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          50 percent) and George owned the other 25 percent.  Additionally,           
          decedent and his family collectively owned 50 percent of the                
          Minn-Kota class B common shares (decedent owned 49.6 percent and            
          his family owned 0.4 percent), and George and his family owned              
          the other 50 percent.  Jody owned 100 percent of the Minn-Kota              
          class A voting common stock.                                                
               After the transfers, decedent's family owned almost 80                 
          percent of Sigco, and George's family owned almost 68 percent of            
          Minn-Kota.  Jody continued to own all of the Minn-Kota voting               
          common stock.                                                               
               Before making these transfers, in which decedent transferred           
          stock valued at $440,467.20 to his brother's family and George              
          transferred stock valued at $382,140 to decedent's family,                  
          neither brother had ever transferred any Sigco or Minn-Kota stock           
          to the other's family.  George transferred 540 shares of Minn-              
          Kota stock to decedent's son, Jay, on December 18, 1996, January            
          2, 1997, and January 2, 1998.6  The value of the stock in each of           
          these transfers was $19,926.  George made no transfers of stock             
          to any other members of decedent's family during this time.                 






               6The parties stipulated that George made no transfers of               
          stock to decedent's children after 1995.  However, the parties              
          agree that stipulation is incorrect and that George made these              
          transfers to Jay at these times.                                            





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