Charles T. McCord, Jr. and Mary S. McCord, Donors - Page 95

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          “economic rights” with regard to the gifted interest and did not            
          consist of all of the donors’ rights as limited partners in that            
          particular limited partnership interest.  Upon petitioners’                 
          transfer and upon CFT’s receipt of the gifted interest in the MIL           
          partnership, petitioners retained, and CFT never received, the              
          following rights associated with petitioners’ interest in MIL               
          (references are to the MIL amended partnership agreement):                  

               (1) The right to vote on MIL partnership matters (section              
               3.10);                                                                 
               (2) The right to redeem the MIL partnership interest                   
               (section 9.02(b));                                                     
               (3) The right to inspect financial and other pertinent                 
               information relating to MIL (section 3.09(d)(i)-(v));                  
               (4) The right to access any properties or assets owned by              
               MIL (section 3.09(d)(vi)); and                                         
               (5) The right to veto early liquidation of MIL, unless such            
               liquidation is required by State law (section 10.01).                  

               Under section 7.02 of the Texas Revised Limited Partnership            
          Act, a partnership agreement may, but is not required to, limit             
          the partnership rights that may be transferred when a partner               
          transfers or assigns an interest in a partnership.  In this case,           
          petitioners made their retention of the above rights (and the               
          nonreceipt thereof by CFT) explicit by the terms of the MIL                 
          partnership agreement that they adopted.  Section 8.03 of the MIL           
          partnership agreement, discussing the transfer of a limited                 







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