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accustomed standards of living, and they decided to follow their
accountants’ recommendations. By that time, all of the disputes
that arose during the prefunding process had been resolved, and
Mr. Stone, Ms. Stone, and the other partners of each of the Five
Partnerships had agreed on the identities and the values of the
assets that they would transfer to each such partnership. Eugene
Earle Stone, IV, had a particular interest in managing, and
maintaining the value of, the preferred stock of Stones, Inc.,
and it was decided that approximately $1 million18 of such stock,
as well as certain other property, was to be transferred to
ES4LP. C. Rivers Stone had a particular interest in managing Mr.
Stone’s Piney Mountain property, and it was decided that various
parcels of that property totaling 366.097 acres, as well as
certain other property, were to be transferred to CRSLP.19 Ms.
18The record does not disclose the precise value of each of
the assets transferred to each of the Five Partnerships as of the
date of each such transfer to each such partnership. However,
the record establishes the precise value of each of the assets
owned by each such partnership on the respective dates of the
deaths of Mr. Stone and Ms. Stone. The parties agree that, after
the gifts by Mr. Stone of certain partnership interests in ES4LP,
CRSLP, RSMLP, and MSFLP (described below) to Eugene Stone, IV, C.
Rivers Stone, Ms. Morris, and Ms. Fraser, respectively, all the
partners of each of those four partnerships (as well as ES3LP)
received, as the Stone family intended and agreed, respective
percentage interests in each such partnership that were propor-
tionate to the fair market value of the assets that such partners
respectively transferred to each such partnership.
19The parties stipulated that a one-percent interest in each
of various parcels totaling 366.949 acres of the Piney Mountain
property was transferred from Mr. Stone to C. Rivers Stone and
(continued...)
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