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(20 shares), an unrelated tax-exempt entity. Decedent, Betsy, and
George were the directors and officers of Turner Corp. Decedent
was the chief executive officer, Betsy was secretary, and George
was treasurer.
An agreement of limited partnership of the Turner Partnership
was executed by all of its partners. Decedent signed on behalf of
Turner Corp.
Decedent, through the 1993 Trust, contributed to the
partnership approximately $1,286,000 of his listed securities, plus
notes receivable due from Betsy’s children. George contributed to
the partnership $1,000 in cash and real property in Vermont valued
at $49,000. At the time of the formation of the Turner
Partnership, decedent held a 95.4-percent limited partnership
interest, George held a 3.54-percent limited partnership interest,
and Turner Corp., as the sole general partner of the Turner
Partnership, held the remaining 1.06 percent.5
The assets of the Turner Partnership (and the values of those
assets) as of July 1993 were as follows:
Shares Value
Decedent’s contribution
Municipal bonds
5 Turner Corp. was to pay $15,000 to the partnership for
its general partnership interest. However, it did not pay the
$15,000 in cash for its interest; rather, the corporation issued a
noninterest bearing promissory note in favor of decedent for its
1.06-percent interest.
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Last modified: May 25, 2011