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total partnership interest in each such partnership than such
partner should have received based on the value of the property
that such partner transferred to any such partnership. In order
to correct the unintended consequences of the valuation errors,
Mr. Stone made a gift as of April 9, 1997, to each of the chil-
dren of the unintended excessive partnership interest in each of
ES4LP, CRSLP, RSMLP, and MSFLP that each such child had received,
as follows:
Donee’s Description of
Name Gift Value of Gift
Eugene Earle Stone, IV 281 General Partner $10,095
Units in ES4LP
Eugene Earle Stone, IV 1 Limited Partner Unit 36
in ES4LP
C. Rivers Stone 1.02 General Partner 50
Units in CRSLP
Ms. Morris 136 General Partner 6,426
Units in RSMLP
Ms. Morris 1 Limited Partner Unit 47
in RSMLP
Ms. Fraser 34 General Partner 1,489
Units in MSFLP
Ms. Fraser 1 Limited Partner Unit 44
in MSFLP
Total Value of Gifts $18,187
After the foregoing gifts were made as of April 9, 1997,40
all the partners of each of the Five Partnerships received, as
the Stone family intended and agreed, respective percentage
interests in each such partnership that were proportionate to the
40The above-described gifts were reported in the 1997 gift
tax return filed on behalf of the deceased Mr. Stone.
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