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The allocation of initial partnership interests was based on
the December 31, 1995, market value of the assets contributed to
the partnership. The appraised market value of the real estate
was $1,860,000. The market value of the securities was
$1,318,609.
B. Petitioner’s Gifts of Partnership Interests
1. The April 19, 1996, Gifts
On April 19, 1996, petitioner transferred a 69.4815368-
percent limited partnership interest, representing the following
gifts: a 66.80917-percent limited partnership interest to
Clarajane as Trustee of the Lappo Generation Trust; and a
0.6680917-percent interest to each of her four grandchildren,
Seth R. Middlecamp, Lisa Middlecamp-Silky, Wendy Thomas, and
Alyson Middlecamp.
2. The July 2, 1996, Gift
On July 2, 1996, petitioner gave her remaining 29.2184632-
percent limited partnership interest to Clarajane in her
individual capacity.
Consequently, after these gifts, the partnership interests
were as follows:
General Limited
Partnership Partnership
Partner Interest Interest Total
Petitioner 1.0 –- 1.0000000
Clarajane .2 29.3184632 29.5184632
Lappo Generation
Trust -- 66.8091700 66.8091700
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Last modified: May 25, 2011