- 3 - 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 66.8091700Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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