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tax and interest totaling $655,594 were paid with respect to Mr.
Stone’s estate. Of that total amount of State estate tax and
interest paid in 1999, ES4LP paid $98,545, CRSLP paid $268,474,
RSMLP paid $151,871, and MSFLP paid $136,704. The funds used to
pay Federal and State estate taxes and interest in 1999 with
respect to Mr. Stone’s estate consisted of non pro rata distribu-
tions to or on behalf of his estate.
The partnership return that ES4LP filed for 1999 reflected
that ES4LP made distributions during that year to its partners
totaling $529,254, as follows: $469,882 to Mr. Stone’s estate,57
$47,749 to Ms. Stone’s estate, $11,602 to Eugene Earle Stone, IV,
and $21 to Anne M. Stone.
ES4LP’s balance sheet for 1999 included a schedule entitled
“Eugene E. Stone IV Limited Partnership, General Ledger, As of
December 31, 1999" (ES4LP’s 1999 general ledger). ES4LP’s 1999
general ledger reflected a check dated March 4, 1999, payable to
Eugene E. Stone, III, in the amount of $469,881.72.58 Another
schedule (capital accounts schedule) included as part of ES4LP’s
57The $469,882 distribution to Mr. Stone’s estate shown in
ES4LP’s 1999 partnership return equals the total amount of
Federal and State estate taxes and interest with respect to Mr.
Stone’s estate that E&Y’s Estate tax allocation schedule re-
flected as payable by ES4LP in 1999.
58The $469,881.72 check reflected in ES4LP’s 1999 general
ledger and rounded to $469,882 equals the total amount of Federal
and State estate taxes and interest with respect to Mr. Stone’s
estate that E&Y’s estate allocation schedule reflected as payable
by ES4LP in 1999. See supra note 57.
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