Estate of W.W. Jones II, Deceased, A.C. Jones IV, Independent Executor - Page 4




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               During his lifetime, decedent acquired, by gift or bequest,            
          the surface rights to several large ranches, including the Jones            
          Borregos Ranch, consisting of 25,669.49 acres, and the Jones Alta           
          Vista Ranch, consisting of 44,586.35 acres.  These ranches were             
          originally acquired by decedent’s grandfather and have been held            
          by decedent’s family for several generations.  The land on these            
          ranches is arid natural brushland, and commercial uses include              
          raising cattle and hunting.                                                 
               Motivated by his desire to keep the ranches in the family,             
          decedent became involved in estate planning matters beginning in            
          1987.  In 1994, decedent’s certified public accountant suggested            
          that decedent use partnerships as estate and business planning              
          tools.  Following up on this suggestion, A.C. Jones prepared                
          various projections for decedent concerning a hypothetical                  
          transfer of the ranches to partnerships and the discounted values           
          that would attach to the partnership interests for gift tax                 
          purposes.                                                                   
               A.C. Jones, Elizabeth Jones, Susan Jones Miller, Kathleen              
          Jones Avery, and Lorine Jones Booth each owned a one-fifth                  
          interest in the surface rights of the Jones El Norte Ranch.  They           
          acquired this ranch by bequest from decedent’s aunt in 1979.  The           
          Jones El Norte Ranch was also originally owned by decedent’s                
          grandfather and has also been owned by decedent’s extended family           
          for several generations.                                                    





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