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an $80,000 check drawn on CRSLP’s bank account, a $599,333 check
drawn on RSMLP’s bank account, and a $461,597 check drawn on
MSFLP’s bank account. In 1998, State estate tax totaling
$437,207 was paid with respect to Mr. Stone’s estate. Of that
total amount of State estate tax paid in 1998, ES4LP paid
$133,029, CRSLP paid $20,000, RSMLP paid $160,536, and MSFLP paid
$123,642.46 The funds used to pay Federal and State estate taxes
in 1998 with respect to Mr. Stone’s estate consisted of non pro
rata distributions to or on behalf of his estate by each of
ES4LP, CRSLP, RSMLP, and MSFLP.
The partnership return that ES4LP filed for 1998 reflected
that ES4LP made distributions during that year to its partners
totaling $639,807 (i.e., $639,288 to Mr. Stone’s estate, $418 to
Ms. Stone, and $101 to Eugene Earle Stone, IV).47
45(...continued)
AWS Trust for the benefit of Ms. Stone and except for his respec-
tive partnership interests in ES4LP, CRSLP, RSMLP, and MSFLP
bequeathed to Eugene Earle Stone, IV, C. Rivers Stone, Ms.
Morris, and Ms. Fraser, respectively.
46The record discloses that ES4LP paid $133,029 to the S.C.
Department of Revenue on Mar. 15, 1998. The record does not
disclose the date on which CRSLP, RSMLP, and MSFLP made State
estate tax payments with respect to Mr. Stone’s estate.
47The only other distribution reflected in ES4LP’s partner-
ship return for 1998 was because of Ms. Stone’s death in that
year. The partnership return that ES4LP filed for 1998 reflected
that ES4LP opened a capital account for Ms. Stone’s estate (Ms.
Stone’s estate’s capital account in ES4LP), and the balance in
Ms. Stone’s capital account as a limited partner was transferred
to Ms. Stone’s estate’s capital account in ES4LP.
(continued...)
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