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finally in repayment to partners of positive capital account
balances.
By a series of transfer documents, Mr. Gulig assigned to
SFLP property of decedent with a fair market value of $9,876,929,
constituting approximately 98 percent of decedent’s wealth, in
exchange for a 99-percent limited partnership interest. The
contributed property included decedent’s interest in specified
real estate (including the residence occupied by decedent),
securities, accrued interest and dividends, insurance policies,
an annuity, receivables, and partnership interests. About
75 percent of the contributed value was attributable to cash and
securities. The majority of the asset transfer documents were
dated August 12, 1994, while change of ownership forms for the
life insurance policies were executed on August 14 and 15, 1994.
Letters dated August 15, 1994, were also sent to the brokers
holding decedent’s securities accounts, to those administering
the contributed partnership interests, and to the borrowers on
notes payable to decedent advising them regarding transfer of the
underlying assets to SFLP. All of the contributed property was
reflected in decedent’s capital account. Brokerage and bank
accounts were opened in the name of the partnership during the
period from August through October.
Mr. Gulig invited the Strangi children to participate in
SFLP through an interest in Stranco. Decedent purchased
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