Clarissa W. Lappo - Page 3

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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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