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fair market value of the assets that such partners respectively
transferred to each such partnership, and the respective assets
that the partners of each such partnership transferred to each
such partnership were credited to the respective capital accounts
of such partners. Upon the termination or dissolution of each of
the Five Partnerships, the partners of each such partnership were
entitled to distributions from each such partnership in amounts
equal to their respective capital accounts.
After the partners of ES3LP made bona fide, arm’s-length
transfers of the respective assets that they owned to that
partnership in exchange for certain partnership interests, the
respective partnership interests owned by the partners of ES3LP
in April 1997 were as follows:
General Limited
Partner Partner
Partner Interests Interests
Mr. Stone 1.001% 68.972%
Ms. Stone -- 29.027%
Eugene Earle Stone, IV .250% --
C. Rivers Stone .250% --
Ms. Morris .250% --
Ms. Fraser .250% --
At the time of Mr. Stone’s death on June 5, 1997, Mr. Stone
held the same percentage partnership interests in ES3LP that he
owned in April 1997. At the time of Ms. Stone’s death on October
16, 1998, Ms. Stone held the same percentage partnership interest
in ES3LP that she owned in April 1997.
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