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which were canceled. This transaction and its effects are
discussed further infra pp. 10-11 and p. 19.
On December 28, 1996, decedent and ISA Trust transferred
their respective shares of Empak stock to WCB Holdings in
exchange for WCB Holdings membership units, which were divided
into class A governance, class A financial, class B governance,
and class B financial units. For a greater discussion of this
transaction, see infra pp. 11-14.
On December 29, 1996, decedent and ISA Trust created the
Bongard Family Limited Partnership (BFLP). Decedent transferred
all of his WCB Holdings class B membership units to BFLP in
exchange for a 99-percent limited partnership interest, and ISA
Trust transferred a portion of its WCB Holdings class B
membership units to BFLP in exchange for a 1-percent general
partnership interest. BFLP is discussed in further detail infra
pp. 19-21.
On March 7, 1997, Empak International merged into Empak,
which resulted in the foreign corporation’s receiving an
ownership interest in Empak and the cancellation of Empak’s
shares in Empak International. Facts regarding this transaction
are set forth infra pp. 14-15.
On March 15, 1997, decedent transferred WCB Holdings class A
membership units to three trusts that he had previously
established. Each of these trusts was established to benefit
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