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and MSFLP. At no time did the partners of RSMLP, including Mr.
Stone and Ms. Stone, commingle the assets that RSMLP owned with
their respective personal assets. At all times, RSMLP was
respected by the Stone family as a separate entity.
In April 1997, the partners of MSFLP made bona fide, arm’s-
length transfers to that partnership, as follows. On April 9,
1997, Mr. Stone transferred to MSFLP his interest in the
1054.415-acre parcel of the Cedar Mountain property and certain
other property, and Ms. Fraser transferred to MSFLP her interest
in that property,36 in exchange for both general and limited
partnership interests.37 On the same date, Ms. Stone transferred
to MSFLP the interest that she owned in the 1054.415-acre parcel
of the Cedar Mountain property in exchange for a limited partner-
ship interest. At a time not disclosed by the record in April
1997, Ms. Davis and Ms. Arnal transferred certain property that
they owned to MSFLP in exchange for both general and limited
36The record is not clear as to why the deed reflecting the
transfer to MSFLP of Ms. Fraser’s interest in the 1054.415-acre
parcel of the Cedar Mountain property showed Ms. Fraser and her
husband Mr. Fraser as the grantors, while the deed reflecting the
transfer by Mr. Stone and Ms. Stone to Ms. Fraser of such inter-
est in that parcel showed the grantee only as Ms. Fraser. We
presume that applicable State law required that not only Ms.
Fraser but also her husband Mr. Fraser be reflected as grantors
on the deed when Ms. Fraser transferred to MSFLP her interest in
the 1054.415-acre parcel of the Cedar Mountain property.
37Although not altogether clear from the record, it appears
that Ms. Fraser also transferred certain other property to MSFLP
in exchange for general and limited partnership interests.
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