Estate of Eugene E. Stone, III, Deceased, C. Rivers Stone, E.E. Stone, IV, Mary Stone Fraser & Rosalie Stone Morris, Co-Personal Representatives - Page 82

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          1997, Mr. Stone transferred to ES4LP some of his preferred stock            
          of Stones, Inc., his interest in the Keith Drive property, and              
          certain other property, and Eugene Earle Stone, IV, transferred             
          to ES4LP his interest in the Keith Drive property, in exchange              
          for both general and limited partnership interests.30  At a time            
          not disclosed by the record in April 1997, Anne M. Stone trans-             
          ferred certain property that she owned to ES4LP in exchange for a           
          general partnership interest.  On April 15, 1997, Ms. Stone                 
          transferred certain property that she owned to ES4LP in exchange            
          for a limited partnership interest.  When the partners of ES4LP             
          formed and funded that partnership, they contemplated and in-               
          tended that ES4LP operate as a joint enterprise for profit for              
          the management of its assets and that Eugene Earle Stone, IV,               
          contribute his services in providing such management.                       
               After the partners of ES4LP transferred the respective                 
          assets that they owned to ES4LP in exchange for certain partner-            
          ship interests, Eugene Earle Stone, IV, began actively managing             
          the assets of ES4LP, as Mr. and Ms. Stone intended.   In this               
          connection, Eugene Earle Stone, IV, on behalf of ES4LP,                     
          managed, and made investment decisions with respect to, ES4LP’s             
          assets.  The respective partnership returns that ES4LP filed for            


               30Although not altogether clear from the record, it appears            
          that Eugene Earle Stone, IV, also transferred certain other                 
          property to ES4LP in exchange for general and limited partnership           
          interests.                                                                  





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