- 37 -
Morris had a particular interest in managing certain of her
parents’ stock and securities, including at least some of Mr.
Stone’s preferred stock in Stones, Inc., and it was decided that
various stock and securities, including approximately $642,000 of
such preferred stock, as well as certain other property, was to
be transferred to RSMLP. Ms. Fraser had a particular interest in
managing her parents’ Cedar Mountain property, and it was decided
that the 1054.415-acre parcel of that property, as well as
certain other property, was to be transferred to MSFLP. All of
the children had a particular interest in the Cherrydale resi-
dence, and it was decided that that property, as well as certain
other property, was to be transferred to ES3LP.
On April 4, 1997, Mr. Stone, as both a general partner and a
limited partner, Eugene Earle Stone, IV,20 C. Rivers Stone, Ms.
Morris, and Ms. Fraser, as general partners, and Ms. Stone, as a
limited partner, executed an amended and restated partnership
19(...continued)
that Mr. Stone and C. Rivers Stone transferred to CRSLP their
respective interests in those 366.949 acres of that property.
Those stipulations are clearly contrary to the deeds relating to
such transfers, and we shall disregard such stipulations. See
Cal-Maine Foods, Inc. v. Commissioner, 93 T.C. 181, 195 (1989).
Those deeds show that a total of 366.097 acres of various parcels
of the Piney Mountain property was the subject of such transfers.
20As of Apr. 4, 1997, Eugene Earle Stone, IV, was no longer
both a general partner and a limited partner of ES3LP; he was
only a general partner.
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