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Partner Percentage Interest
Mark W. Senda, Trustee, or his 1.0 General
successors in trust, under the Mark W.
Senda Revocable Trust dated Feb. 23,
1998, and any amendments thereto
Mark W. Senda, Trustee, or his 97.97 Limited
successors in trust, under the Mark W.
Senda Revocable Trust dated Feb. 23,
1998, and any amendments thereto
Michele Senda 1.0 Limited
Citicorp Trust South Dakota and Robert 0.01 Limited
Brendell, Trustees of the
Mark R. Senda Irrevocable Trust
Citicorp Trust South Dakota and Robert 0.01 Limited
Brendell, Trustees of the
Ross J. Senda Irrevocable Trust
Citicorp Trust South Dakota and Robert 0.01 Limited
Brendell, Trustees of the Janell N.
Senda Irrevocable Trust
On December 20, 1999, petitioners contributed to SFLP II
18,477 shares of stock in exchange for their partnership
interests. Petitioners transferred the stock from their joint
brokerage account to the brokerage account of SFLP II. Both
accounts were held at Salomon Smith Barney. Trusts for the
children purportedly contributed oral accounts receivable in
exchange for their partnership interests. The accounts
receivable, however, were never reduced to writing, had no terms
for repayment, and had not been paid as of the time of trial. On
that same day, petitioner gave to each child, in trust, a
17.9-percent limited partnership interest in SFLP II. The
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Last modified: May 25, 2011