- 8 -
general partner and a 4.5-percent interest as limited partner.
Petitioners’ children, Daniel J. Runkle, Dustin S. Runkle, and
Dawn A. Runkle, each held 29-percent interests as limited
partners in the Elknur Family Limited Partnership from its
formation through at least December 31, 1995.
Petitioners transferred title to their personal residence to
the Elknur Family Limited Partnership by quitclaim deed, dated
October 18, 1994, in accordance with their partnership agreement.
Petitioners received no consideration in exchange for their
transfer of their personal residence to the Elknur Family Limited
Partnership. The quitclaim deed referenced the consideration as
“one dollar and other valuable consideration.” Moreover, despite
their contribution to the partnership, petitioners remained
obligated to pay the outstanding obligations on the residence.
Petitioners opened a business checking account for the
Elknur Family Limited Partnership on September 14, 1994, and Mr.
Runkle deposited insurance commission checks into the business
checking account for the Elknur Family Limited Partnership during
1994 and 1995. Petitioners used the partnership’s checking
account to pay personal expenses, including doctor bills and loan
payments. Petitioners caused the Elknur Family Limited
Partnership to file Form 1065, U.S. Partnership Return of Income,
for 1994 and every year thereafter.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011