- 93 -
The partnership return that MSFLP filed for 1999 reflected
that MSFLP made distributions during that year to Mr. Stone’s
estate totaling $805,69361 and did not make distributions during
that year to any of its other partners.
A 1999 profit and loss statement for MSFLP (MSFLP’s 1999
profit and loss statement) reflected an expense of $805,692.6762
for “Tax: Fed”.
On October 16, 1998, Ms. Stone died at the age of 86.
Pursuant to Mr. Stone’s will, upon the death of Ms. Stone, any
assets remaining in the AWS Trust were to be distributed equally
to the children.
On the date of Ms. Stone’s death, the AWS Trust held a
69.973 percent limited partnership interest in ES3LP,63 the assets
61The $805,693 distribution to Mr. Stone’s estate shown in
MSFLP’s 1999 partnership return exceeds the total amount of
Federal and State estate taxes and interest with respect to Mr.
Stone’s estate (i.e., $650,899) that E&Y’s Estate tax allocation
schedule reflected as payable by MSFLP in 1999.
62The $805,692.67 expense reflected in MSFLP’s 1999 profit
and loss statement and rounded to $805,693 exceeds the total
amount of Federal and State estate taxes and interest with
respect to Mr. Stone’s estate (i.e., $650,899) that E&Y’s Estate
tax allocation schedule reflected as payable by MSFLP in 1999.
See supra note 61.
63On June 5, 1997, the date of Mr. Stone’s death, Mr. Stone
held a 1.001 percent general partnership interest and a 68.972
percent limited partnership interest in ES3LP. Both of those
interests were transferred to the AWS Trust pursuant to Mr.
Stone’s will. The parties stipulated that on Oct. 16, 1998, the
date of Ms. Stone’s death, the AWS Trust held a 69.973 percent
limited partnership interest in ES3LP. We presume that after Mr.
(continued...)
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