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WCB Class A Class A Class B Class B
Holdings governance financial governance financial
member units/percentunits/percentunits/percent units/percent
Decedent 287,620/48.39 287,620/48.390/0 0/0
ISA 80,860/13.61 80,860/13.61 681,060/12.73 681,060/12.73
Trust
BFLP 0/0 0/0 4,667,844/87.27 4,667,844/87.27
CH Trust 77,262/13 77,262/13 0/0 0/0
GC Trust 77,262/13 77,262/13 0/0 0/0
QTIP 71,319/12 71,319/12 0/0 0/0
Trust
Total 594,323/100 594,323/100 5,348,904/100 5,348,904/100
Decedent reported the funding of CH Trust, GC Trust, and
QTIP trust on a Federal gift tax return for 1997. The values
reported on the gift tax return were consistent with a valuation
report prepared as of December 15, 1996, before WCB Holdings’s
formation.
D. Decedent’s Transfer of BFLP Interest to Cynthia Bongard
On December 10, 1997, decedent made a gift representing a
7.72-percent ownership interest in BFLP to Cynthia Bongard.
BFLP’s ownership was then as follows:
BFLP partner Partnership interest &
type
ISA Trust 1%, general partner
Decedent 91.28%, limited
partner1
Cynthia 7.72%, limited
partner
1 Decedent owned this interest until his death.
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