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those units to Mrs. Burke. He also withdrew the income rights
associated with 540 B units from decedent’s trust and assigned
the income rights associated with 60 B units to each of
decedent’s grandchildren.
Mr. Bigelow, for himself and under decedent’s power of
attorney, acting as trustee of decedent’s trust, signed a
statement of ownership in which he certified that the ownership
of Spindrift limited partnership units as of July 18, 1997, was:
Partner A Units B Units
Decedent’s trust 1 8,250
Estate of Mrs. Fitzgerald, deceased 1 2,500
Mrs. Burke 1 2,700
Mr. Bigelow 1 1,050
Total 4 14,500
He also certified that decedent’s grandchildren owned the income
rights associated with 1,800 B units (200 units each) owned by
the general partner. The grandchildren were not substituted as
limited partners as a result of the gifts of income rights.
Disregarding the limited partnership interests associated
with the income rights transferred to decedent’s grandchildren,
decedent’s trust owned a 1-percent general partnership interest
and a 45-percent ((8,250 - 1,800) � 14,500) limited partnership
interest in the partnership when decedent died on August 8, 1997.
J. Termination of the Partnership
The partnership did not make any distributions to its
partners with respect to their interests in the partnership
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Last modified: May 25, 2011