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partnership interests. When the partners of MSFLP formed and
funded that partnership, they contemplated and intended that
MSFLP operate as a joint enterprise for profit for the management
of its assets and that Ms. Fraser contribute her services in
providing such management.
After the partners of MSFLP transferred the respective
assets that they owned to MSFLP in exchange for certain partner-
ship interests, Ms. Fraser began actively managing the assets of
MSFLP, as Mr. and Ms. Stone intended. In this connection, Ms.
Fraser, on behalf of MSFLP, began actively managing MSFLP’s Cedar
Mountain property, which included maintaining the roads and lakes
that Mr. Stone had built on that property. In addition, the
respective partnership returns that MSFLP filed for 1998 and 1999
reflected that MSFLP made investment decisions to sell certain of
its stock for substantial gains.38 Ms. Fraser also hired on
behalf of MSFLP advisors and accountants who at all times were
different from those of ES3LP, ES4LP, CRSLP, and RSMLP. At no
time did the partners of MSFLP, including Mr. Stone and Ms.
Stone, commingle the assets that MSFLP owned with their respec-
tive personal assets. At all times, MSFLP was respected by the
Stone family as a separate entity.
The respective assets that Mr. Stone and Ms. Stone retained,
38Although not altogether clear from the record, it appears
that MSFLP reinvested the proceeds from the sale of its stock.
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