Estate of Theodore R. Thompson, Deceased, Betsy T. Turner, Executrix - Page 8




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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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