Estate of Eugene E. Stone, III, Deceased, C. Rivers Stone, E.E. Stone, IV, Mary Stone Fraser & Rosalie Stone Morris, Co-Personal Representatives - Page 87

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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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