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fide, arm’s-length transfers.
On the record before us, we reject respondent’s contention
that, because Mr. Stone and Ms. Stone did not actively partici-
pate in the negotiations by the children, the respective trans-
fers of assets by Mr. Stone and Ms. Stone to each of the Five
Partnerships were not bona fide, arm’s-length transfers. Each
member of the Stone family was represented by his or her own
independent counsel and had input into the decision-making as to
how each of the Five Partnerships was to be structured and oper-
ated and what property was to be transferred to each such part-
nership. The Stone family understood that Mr. Stone and Ms.
Stone would not be bound by any agreements that the children were
able to reach as a result of the children’s negotiations and that
Mr. Stone and Ms. Stone would make the ultimate decision as to
which, if any, of their respective assets to transfer to each of
the Five Partnerships. In this connection, although Mr. Stone
and Ms. Stone agreed to form the Five Partnerships, they did not
intend to, and did not, transfer all their respective assets to
such partnerships. Instead, they retained sufficient assets to
enable them to maintain their respective accustomed standards of
living. Mr. Stone and Ms. Stone did not accept the children’s
recommendations resulting from the children’s negotiations re-
garding the structure, funding, and operation of the Five Part-
nerships without thought, comment, or question. For example, it
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