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Slater’s names. In exchange for the $30,000 paid to the DAC FLP,
Ms. Cawley received an additional 5.178-percent interest in the
DAC FLP, and in exchange for the $40,000 paid to the DAS FLP, Ms.
Slater received an additional 6.904-percent interest in the DAS
FLP.
On March 1 and April 4, 1997, Ms. Cawley wrote two checks to
the DAC FLP, each in the amount of $25,000, and in exchange for
these amounts paid to the DAC FLP, she received an additional
8.64-percent interest in the DAC FLP. Similarly, on March 5 and
April 8, 1997, Ms. Slater wrote two checks to the DAS FLP, each
in the amount of $25,000, and in exchange for the amount paid to
the DAS FLP, Ms. Slater received an additional 8.63-percent
interest in the DAS FLP.
In each of 1995, 1996, and 1997, decedent, through her
limited guardian ad litem, made gifts of 1.726-percent interests
in the DAS FLP to Ms. Slater, her husband, and their two
children. Likewise, gifts were made of 1.726-percent interests
in the DAC FLP to Ms. Cawley, her husband, and their three
children in each of 1995, 1996, and 1997. Similarly, gifts of
1.803-percent interests in the RMA FLP were made to Mr. Richard
Abraham and his family in 1995, 1996, and 1997.18
18During 1995, 1996, and 1997, decedent gifted a total
23.439 percent of the RMA FLP to Mr. Richard Abraham and his
family.
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