MARK W. SENDA AND MICHELE SENDA - Page 6

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          Senda & Associates, L.P.                                                    
               Sometime in 1999, Dankenbring advised petitioner that, if              
          petitioner wished to transfer additional property in partnership            
          form to the children, he should form a second FLP instead of                
          recapitalizing SFLP I.                                                      
               On December 2, 1999, the secretary of state of Missouri                
          issued a certificate of limited partnership for Senda &                     
          Associates, L.P. (SFLP II).  On December 4, 1999, Robert Brendell           
          signed, as trustee, the irrevocable trusts (trusts) for the                 
          benefit of each child.  Petitioner and Senda, however, did not              
          sign the trusts as “trustmakers” until May 1 and 11, 2000,                  
          respectively.  Although the trusts also list Citicorp Trust South           
          Dakota (Citicorp) as trustee, a representative of Citicorp never            
          signed the trusts.                                                          
               On December 17, 1999, petitioners signed the SFLP II                   
          Partnership Agreement (SFLP II Agreement).  The partnership                 
          interests, as set forth in the SFLP II Agreement, were initially            
          held as follows:                                                            
















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