-7-
respond to those laws by transferring the residence to a family
general partnership. According to Curto, decedent could then
give all of her interest in the partnership to her family,
continue to live at the residence as a tenant of the partnership,
and remove the residence from the reach of the Federal estate
tax.
Decedent followed Curto’s advice. On December 10, 1993, at
almost 72 years of age, decedent (together with her children and
children-in-law) executed a general partnership agreement
(partnership agreement) forming Funny Hats.4 Curto and his firm
prepared all of the documentation for that purpose. As stated in
the partnership agreement, the partners of Funny Hats and their
partnership interests were as follows:
Partner Partnership Interest
Martha Johnson 7.1875%
Robert Johnson 7.1875
Nancy Kerrigan 7.1875
Patrick Kerrigan 7.1875
Linda Labet 7.1875
Michael Labet 7.1875
David Wishart 7.1875
Sarah Disbrow 7.1875
David Disbrow1 14.3750
Decedent 28.1250
100.0000
1 David Disbrow was decedent’s only unmarried
child at the time Funny Hats was formed, and he
received an interest in Funny Hats equal to the
interest of each married couple.
4 The record does not explain the reason for the name “Funny
Hats”.
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