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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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