Estate of Eugene E. Stone, III, Deceased, C. Rivers Stone, E.E. Stone, IV, Mary Stone Fraser & Rosalie Stone Morris, Co-Personal Representatives - Page 76

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                         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-                   





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