Estate of Charles Porter Schutt, Deceased, Charles P. Schutt, Jr., and Henry I. Brown III, Co-Executors - Page 15

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          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.                                                                      





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