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partnership, the Trust, and decedent; M.L. Stern & Co. statements
for the partnership and the Trust; Putnam Investments statements
for the partnership and the Trust; Franklin Funds statements for
the partnership and the Trust; the Rockefeller Center Properties
stock certificate; and the Marsh note.
Mr. Blankstein set up a general ledger for HFLP to
categorize and account for all transactions affecting partnership
assets and income beginning June 14, 1994. Capital accounts were
established for each partner, as well as ledger accounts to show
distributions to partners, income received by the partnership on
the various portfolio assets, proceeds from the sale of
securities, and costs and charges incurred. In addition, an
account labeled “Receivable from Trust” was created primarily to
reflect amounts received by the Trust after June 14, 1994, that
should properly have been received by the partnership. This
account was presumably necessitated in large part by the delay in
transferring title to the portfolio securities and in opening the
partnership bank account. The balance in this account was then
treated as a distribution to the Trust; no funds were actually
transmitted between the two entities. Mr. Blankstein also
conceded that several items which should have been attributed to
the partnership were omitted.
A Form 709, United States Gift (and Generation-Skipping
Transfer) Tax Return, and a Form 706, United States Estate (and
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