- 4 - Partner Percentage Interest Mark W. Senda, Trustee, or his 10.0 General successors in trust, under the Mark W. Senda Revocable Trust dated Nov. 20, 1996, and any amendments thereto Mark W. Senda, Trustee, or his 89.8397 Limited successors in trust, under the Mark W. Senda Revocable Trust dated Nov. 20, 1996, as amended thereto Michele Senda 0.1303 Limited Mark W. Senda, as trustee for 0.010 Limited Mark R. Senda Mark W. Senda, as trustee for 0.010 Limited Ross J. Senda Mark W. Senda, as trustee for 0.010 Limited Janell N. Senda Although the children’s partnership interests were purportedly held for them in trust, there was no written trust agreement at the time of the transfers reflecting that the children were beneficiaries of any trust for which petitioner was the trustee. The children, as limited partners, reported income/losses from SFLP I on their individual tax returns. Trusts for the benefit of the children and of which petitioner was trustee have never filed tax returns. On December 28, 1998, petitioners contributed to SFLP I 28,500 shares of stock in exchange for their partnership interests. Petitioners transferred the stock from their joint brokerage account to the brokerage account of SFLP I. Both accounts were held at Salomon Smith Barney. The children (orPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011