- 61 - ship, or such child’s estate, as the case may be, shall be responsible for the payment of any such remaining taxes. (b) Except as provided in subparagraph (c) below, I direct that any taxes which may be assessed or imposed by Section 2035(c) of the Internal Revenue Code, as amended, or corresponding provision of state law, including any inter- est or penalties thereon, as a result of any gift tax paid or payable with respect to any interest in any limited partnerships estab- lished for my children which were the subject of any gifts made by me during my lifetime, shall be paid out of and charged equally against such limited partnerships. In the event there are insufficient assets in a limited partnership established for a child of mine to pay an equal amount of such taxes, then the child of mine who received a gift of an interest in such limited partnership, or such child’s estate, as the case may be, shall be responsible for the payment of an equal amount of any such remaining taxes. (c) In the event the Internal Revenue Service or any other taxing authority changes the value attributable to (i) any assets I have con- tributed to a limited partnership established for a child of mine * * * then I direct that all gift, estate, generation-skipping trans- fer, inheritance, transfer, succession, death or similar taxes which may be assessed or imposed as a result of such change in value, * * * shall be paid out of and charged against the limited partnership that received such contribution, or was the subject of such gift, as the case may be. In the event there are insufficient assets in a limited partner- ship established for a child of mine to pay such taxes, then the child of mine who re- ceived such gift, or whose limited partner- ship received such contribution, or such child’s estate, as the case may be, shall be responsible for the payment of any such re- maining taxes. (d) I direct that all other estate, generation-Page: Previous 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 Next
Last modified: May 25, 2011