- 8 - benefits above can be achieved while total control of all assets is retained by the directors of the Corporate General Partner.” The decision to form the family limited partnerships was made approximately a week later at a meeting at Betsy and George’s home attended by decedent, Betsy, George, Robert, and Messrs. Cheleden and Warder. On March 26, 1993, George P. Brown, president of APS, wrote to decedent, Betsy, and Robert. Mr. Brown outlined the services APS agreed to provide in implementing the Fortress Plan. He further explained that the fee for those services would be $32,000, which fee would be shared with Mr. Cheleden. A letter of the same date from Mr. Cheleden to decedent, Betsy, and Robert accompanied the March 26, 1993, letter from APS. In his letter, Mr. Cheleden stated that the Fortress Plan was designed to protect assets from third party claims, maximize the amount that passes to heirs, and “allow the Family to maintain control, to the extent possible, consistent with the above.” He advised decedent, Betsy, and Robert that the limited partnership interests were “expected to enjoy the benefit of ‘discounting’ for gifts and estate tax valuation purposes.” Mr. Cheleden indicated that a 40-percent discount was a realistic expectation. Decedent, Robert, Betsy, and George agreed to form two family limited partnerships and two corporations to serve as the corporate general partners-–the Turner Partnership and Turner Corp. forPage: 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