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conveyance of the Assigned Partnership Interest and the admission
of Assignee as a Class A Limited Partner of the Partnership have
been duly obtained and are evidenced by the signatures hereto”.
All of the initial MIL partners executed the Southfield
agreement.
Further Assignments
On January 12, 1996 (the valuation date), petitioners, as
assignors, entered into an assignment agreement (the assignment
agreement) with respect to their class B limited partnership
interests in MIL. The other parties to the assignment agreement
(the assignees) were the children, four trusts for the benefit of
the children (the trusts), and two charitable organizations-–
Communities Foundation of Texas, Inc. (CFT) and Shreveport
Symphony, Inc. (the symphony). By the assignment agreement,
petitioners relinquished all dominion and control over the
assigned partnership interests and assigned to the assignees all
of their rights with respect to those interests. The assignment
agreement does not contain language similar to that quoted above
from the Southfield agreement regarding the admission of the
assignees as partners of the partnership, and two of the partners
of the partnership, McCord Brothers Partnership and the
foundation, did not execute the assignment agreement in any
capacity. The interests that petitioners assigned to the
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Last modified: May 25, 2011