- 69 -
April 15, 1997, Ms. Stone transferred property that she owned to
CRSLP in exchange for a limited partnership interest. When the
partners of CRSLP formed and funded that partnership, they
contemplated and intended that CRSLP operate as a joint enter-
prise for profit for the management of its assets and that C.
Rivers Stone contribute his services in providing such manage-
ment.
After the partners of CRSLP transferred the respective
assets that they owned to CRSLP in exchange for certain partner-
ship interests, C. Rivers Stone began actively managing the
assets of CRSLP, as Mr. and Ms. Stone intended. In this connec-
tion, C. Rivers Stone, on behalf of CRSLP, began a major project
to convert CRSLP’s Piney Mountain property into a high-end real
property development which was to be known as Montebello and
which was to consist of over 1,000 houses, with, inter alia,
clubhouses for meetings and weddings, as well as shopping cen-
ters. In addition, the partnership return that CRSLP filed for
1997 reflected that CRSLP made investment decisions to sell
certain of its stock for a substantial gain.33 Moreover, the
respective partnership returns that CRSLP filed for 1997, 1998,
and 1999 reflected that CRSLP rented various real properties that
it owned (other than the Piney Mountain property) from which it
33Although not altogether clear from the record, it appears
that CRSLP reinvested the proceeds from the sale of its stock in,
inter alia, certain real estate.
Page: Previous 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 NextLast modified: May 25, 2011