- 68 -
1997 and 1999 reflected that ES4LP sold certain of its stock for
substantial gains.31 Eugene Earle Stone, IV, also hired on
behalf of ES4LP advisors and accountants who at all times were
different from those of ES3LP, CRSLP, RSMLP, and MSFLP. At no
time did the partners of ES4LP, including Mr. Stone and Ms.
Stone, commingle the assets that ES4LP owned with their respec-
tive personal assets. At all times, ES4LP was respected by the
Stone family as a separate entity.
In April 1997, the partners of CRSLP made bona fide, arm’s-
length transfers to that partnership, as follows. On April 9,
1997, Mr. Stone transferred to CRSLP his interest in each of
various parcels totaling 366.097 acres of the Piney Mountain
property and certain other property, and C. Rivers Stone trans-
ferred to CRSLP his interest in each of those parcels, in ex-
change for both general and limited partnership interests.32 At
a time not disclosed by the record in April 1997, Charles R.
Stone, Jr., transferred certain property that he owned to CRSLP
in exchange for both limited and general partnership interests,
and Frances O. Stone transferred certain property that she owned
to CRSLP in exchange for a limited partnership interest. On
31Although not altogether clear from the record, it appears
that ES4LP reinvested the proceeds from the sale of its stock in
1997 and 1999 in certain real estate.
32Although not altogether clear from the record, it appears
that C. Rivers Stone also transferred certain other property to
CRSLP in exchange for general and limited partnership interests.
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