- 5 - 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 valuePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011