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Following the August 1, 1986, sale, the general partnership
managed all the assets, including all the timber and pecan trees,
on the land held by the limited partnership, and reported all
timber and pecan business sales and expenses on all of the land
held by the limited partnership.
On May 1, 1987, the executors of the Forbes estate conveyed
to the QTIP trustee the Forbes estate’s interest in the limited
partnership by endorsing the certificate of limited partnership
units.
Termination of the Limited Partnership and the General
Partnership
On October 7, 1988, Betty and Walter executed a Partnership
Termination, Division and Release Agreement (the termination
agreement), terminating both the limited partnership and the
general partnership, effective December 31, 1987. In the
termination agreement, Walter and Betty agreed that the assets of
the limited partnership and the general partnership would be
distributed so that Walter and Betty would each receive equal net
values, based upon independent appraisals, and that the QTIP
trust would continue to have a 42-percent undivided interest in
all of the land, excluding improvements, crops, trees, and
profits. By the termination agreement, Walter and Betty agreed
4(...continued)
that the Forbes estate claimed and was allowed a deduction for
property interests in excess of those with which the executor of
his estate funded the QTIP trust.
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Last modified: May 25, 2011