-15- December 23, 1994, created the Schutt Family Limited Partnership. On behalf of himself and the two children, decedent contributed to the partnership Alabama timberlands,6 securities, and cash. In return for these contributions (or deemed contributions), the partners received units in the entity representing the following interests: Charles Porter Schutt: 5-percent general partnership interest 82.112-percent limited partnership interest Charles P. Schutt, Jr.: 1-percent general partnership interest 5.444-percent limited partnership interest Caroline Schutt Brown: 1-percent general partnership interest 5.444-percent limited partnership interest Thereafter, decedent began making annual gifts of limited partnership interests, apparently intended to qualify for the exclusion under section 2503(b), to certain of his children, their spouses, and their children. Decedent’s Lifestyle and Health At some time after his first wife’s death and prior to May of 1994, decedent remarried, and he remained married to Greta Brown Layton-Schutt at the time of his death. During the 1995 through 1998 period, decedent led an active lifestyle. This 6 Decedent had acquired interests in Alabama timberlands with two of his brothers-in-law during the 1960s. Portions of decedent’s interests in the timberlands and related operations were placed in trust in 1971, see supra note 2, portions were used in funding the Schutt Family Limited Partnership, and still other portions continued to be owned outright by decedent at his death.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011