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a Delaware limited partnership (the partnership). Petitioner
contributed cash and securities with a designated value of
$2,013,765 to the partnership in exchange for a 0.5-percent
general partner interest and a 99.4-percent limited partner
interest in the partnership, which, collectively, represented
2,013.765 partnership units. Petitioner’s son contributed $1,000
to the partnership in exchange for a 0.05-percent general partner
interest in the partnership, which represented one partnership
unit. The trust contributed $1,000 to the partnership in
exchange for a 0.05-percent limited partner interest in the
partnership, which also represented one partnership unit.
Transfers of Partnership Units
Also on the valuation date, petitioner made three transfers
of partnership units. Petitioner gratuitously transferred 9.0788
partnership units (representing 0.45 percent of all partnership
units outstanding) to his son, to be held in the capacity of a
general partner. Petitioner also gratuitously transferred
916.667 partnership units (representing 45.47 percent of all
partnership units outstanding) to the trust, to be held in the
capacity of a limited partner. Petitioner transferred an
additional 1,077.9409 partnership units (representing 53.48
percent of all partnership units outstanding) to the trust, to be
held in the capacity of a limited partner, in exchange for the
trust’s promissory note in the amount of $646,764. After the
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Last modified: May 25, 2011