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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. for
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Last modified: May 25, 2011