Estate of Eugene E. Stone, III, Deceased, C. Rivers Stone, E.E. Stone, IV, Mary Stone Fraser & Rosalie Stone Morris, Co-Personal Representatives - Page 19

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         that partnership, they contemplated and intended that CRSLP                  
         operate as a joint enterprise for profit for the management of               
         its assets and that C. Rivers Stone contribute his services in               
         providing such management.  After the funding of CRSLP in April              
         1997, C. Rivers Stone began actively managing the assets of that             
         partnership, as Mr. Stone and Ms. Stone intended.  When the                  
         partners of RSMLP formed and funded that partnership, they con-              
         templated and intended that RSMLP operate as a joint enterprise              
         for profit for the management of its assets and that Ms. Morris              
         contribute her services in providing such management.  After the             
         funding of RSMLP in April 1997, Ms. Morris began actively manag-             
         ing the assets of that partnership, as Mr. Stone and Ms. Stone               
         intended.  When the partners of MSFLP formed and funded that                 
         partnership, they contemplated and intended that MSFLP operate as            
         a joint enterprise for profit for the management of its assets               
         and that Ms. Fraser contribute her services in providing such                
         management.  After the funding of MSFLP in April 1997, Ms. Fraser            
         began actively managing the assets of that partnership, as Mr.               
         Stone and Ms. Stone intended.                                                
              On the record in the instant cases, we find that, unlike the            
         transfers involved in Estate of Harper and other cases factually             
         similar to that case, the respective transfers at issue by Mr.               
         Stone and Ms. Stone did not constitute “circuitous ‘recycling’ of            







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