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counts” for 1998 (CRSLP’s 1998 trial balance worksheets) re-
flected the following adjustments to an account identified as “C.
Rivers Stone-Draws”: $510, $26,390, $66,721, $6,063, $316, and
$100,000, or a total of $200,000 of adjustments to that account.
CRSLP’s 1998 trial balance worksheets included a schedule enti-
tled “C. Rivers Stone LLP ‘98, Montebello Actual Expenses
(2/9/99)” (CRSLP’s 1998 Montebello expense schedule). CRSLP’s
1998 Montebello expense schedule reflected in pertinent part the
following entries:
Vendor March 1998 1998 Totals
Estate Taxes $0 $0
Estate Taxes: AW Stone 4 Lots 510 510
Estate Taxes: Commercial 26,390 26,390
Estate Taxes: Residential 66,721 66,721
Estate Taxes: Securities 6,063 6,063
Estate Taxes: Tulip Street Rental 316 316
The foregoing amounts, which total $100,000,50 are identical to
49(...continued)
Ms. Stone’s capital account as a limited partner was transferred
to Ms. Stone’s estate’s capital account in CRSLP.
Because of Mr. Stone’s death in 1997, in that year, as
reflected in the partnership return that CRSLP filed for 1997,
CRSLP opened a capital account for his estate (Mr. Stone’s
estate’s capital account in CRSLP), and the balances in Mr.
Stone’s capital accounts in CRSLP as a general partner and a
limited partner were transferred to Mr. Stone’s estate’s capital
account in CRSLP. The partnership return that CRSLP filed for
1997 showed that CRSLP did not make distributions during that
year to any of its other partners.
50The $100,000 expenditure shown in CRSLP’s 1998 Montebello
expense schedule equals the total amount of Federal and State
estate taxes with respect to Mr. Stone’s estate that E&Y’s Estate
(continued...)
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