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assets. After all, distributing 1 percent to Stranco would not
in any substantial way operate to curb decedent’s ability to
benefit from SFLP property. Accordingly, we direct our attention
to the purpose, as opposed to the mechanics, of partnership
distributions and expenditures.
The record reveals several instances where SFLP expended
funds in response to a need of decedent or his estate. SFLP paid
for Ms. Stone’s back surgery to alleviate an injury she sustained
in caring for decedent prior to the formation of SFLP. In 1994,
SFLP expended nearly $40,000 for funeral expenses, estate
administration, and related debts, including a $19,810.28 check
to Olsten to pay for nursing services rendered to decedent before
his death. These sums were followed in 1995 and 1996 by further
payment of over $65,000 for estate expenses and a specific
bequest. SFLP also disbursed approximately $3 million directed
toward decedent’s estate and inheritance taxes.
The estate seeks to justify these payments primarily by
emphasizing that they were accounted for on SFLP’s books as
advances to partners and later closed as distributions, with pro
rata amounts either advanced or distributed to Stranco. The
evidence also indicates that the $65,000-plus amount was repaid
in January 1997. The estate further explains that certain of
these payments from SFLP were necessitated by the delay in
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