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6. Loans/Notes
The Turner Partnership was used to continue decedent’s
practice of lending money to Betsy’s children and grandchildren.
In April 1994, the Turner Partnership lent $35,000 to Betsy’s son
Robert and his wife. In October 1994, the principal of the loan
was increased to $45,000 and subsequently increased to $50,000. In
October 1994, the Turner Partnership lent $15,000 to Betsy’s son
Bill; it lent an additional $8,000 to Bill in May 1995. The Turner
Partnership maintained records of the amounts that were owed and
paid on the loans.
Each partnership determined the current rate of interest to be
charged on the loans. Although monthly interest payments were
provided as a term on the loans held by the partnerships, those
interest payments were often either late or not paid at all. The
principal of such loans was payable on demand. When a principal
payment was made, often the loan was reamortized and subsequent
interest payments reduced. No enforcement action was taken against
any family member/borrower when payment on the loans was not made.
No loans were made to anyone outside the Turner/Thompson family.
C. Operation of the Thompson Partnership
Robert lived on the 312-acre Norwood Ranch in Colorado both
before and after it was contributed to the partnership. After he
contributed the ranch to the partnership, he entered into a lease
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