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prior to the termination date without the written consent of the
general partners.
Partners may freely transfer their partnership units to or
for the benefit of certain family members and charitable
organizations (permitted transferees). A partner desiring to
transfer his partnership units to someone other than a permitted
transferee must first offer those units to the partnership on the
same terms and conditions. The partnership then has 30 days to
exercise its option to purchase such units. Regardless of the
identity of the transferee, no transferee of partnership units
can attain the legal status of a partner in the partnership
without the unanimous consent of all general partners.
Limited partners have no right to participate in the
management of the partnership’s affairs, and partnership
distributions are subject to the discretion of the general
partners.
The Gift Tax Return
Petitioner timely filed Form 709, United States Gift (and
Generation Skipping Transfer) Tax Return, for 1997 (the Form
709). In a statement attached to the Form 709, petitioner
reported his gratuitous transfer of 9.0788 partnership units to
his son at a value of $9,070. In the same statement, petitioner
reported his gratuitous transfer of 916.667 partnership units to
the trust at a value of $550,000. In another attachment to the
Form 709, petitioner disclosed that he had determined the value
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Last modified: May 25, 2011