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the amount of Federal and State estate taxes and interest that
each such partnership was to pay in 1999, which were attributable
to the inclusion in Mr. Stone’s estate of the total partnership
interest in each such partnership held by Mr. Stone on the date
of his death. E&Y’s Estate tax allocation schedule provided as
follows:
ES4LP CRSLP RSMLP MSFLP
1998 Federal $496,642.00 $80,000.00 $599,333.00 $461,597.00
estate tax
1998 State 133,029.00 20,000.00 160,536.00 123,642.00
estate tax ___________ _____________ ___________ ___________
1998 TOTAL $629,671.00 $100,000.00 $759,869.00 $585,239.00
Federal and
State estate
taxes
1999 Federal $371,336.72 $1,000,641.91 $571,597.34 $514,194.67
estate tax
and interest
1999 State 98,545.00 268,474.00 151,871.00 136,704.00
estate tax
and interest ___________ ____________ ___________ ___________
1999 TOTAL $469,881.72 $1,269,115.91 $723,468.34 $650,898.67
Federal and
State estate
taxes and
interest
GRAND TOTAL $1,099,552.72 $1,369,115.91 $1,483,337.34 $1,236,137.67
On March 5, 1998, the Internal Revenue Service (IRS) re-
ceived a total of $1,698,074 in payments for the anticipated
estate tax with respect to Mr. Stone’s estate. Those payments
consisted of a $60,502 check drawn on the bank account of Mr.
Stone’s estate,45 a $496,642 check drawn on ES4LP’s bank account,
45The estate tax of $60,502 paid by Mr. Stone’s estate was
attributable to the inclusion in his estate of all the property
that he owned on the date of his death except for his properties,
including his partnership interest in ES3LP, to be held by the
(continued...)
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