Estate of Eugene E. Stone, III, Deceased, C. Rivers Stone, E.E. Stone, IV, Mary Stone Fraser & Rosalie Stone Morris, Co-Personal Representatives - Page 16

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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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