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children, acting as cotrustees of the Lillie Investment Trust,
had written Merrill Lynch to instruct it to transfer the funds
from the Merrill Lynch trust account to a new account that the
letter directed Merrill Lynch to open in the name of the LRFLP.
On October 1, 1996, Merrill Lynch opened account No. 69F-07047
(Merrill Lynch LRFLP account) in the name of the LRFLP.
Following the transfer of the assets from the Merrill Lynch trust
account to the Merrill Lynch LRFLP account, the Merrill Lynch
trust account was closed. After the transfer, there was no
material change in the manner in which the transferred assets
were managed.
Also on October 11, 1996, before the general partners of the
LRFLP had contributed any funds to the LRFLP, decedent’s
daughter, acting as decedent’s attorney-in-fact, gave each of
decedent’s children a 16.4672-percent limited partnership
interest in the LRFLP. On October 24 and 30, 1996, decedent’s
children contributed $12,145 apiece, a total of $24,290, to the
capital of the LRFLP as consideration for their initial
.5-percent general partnership interests.8 The $24,290
8 Decedent (through her daughter as decedent’s
attorney-in-fact) gave her son a $10,000 cash gift approximately
2 months later. As mentioned earlier, decedent (through her
daughter as decedent’s attorney-in-fact) also gave the other cash
gifts on Dec. 31, 1995, and Jan. 1, 1996, to her children and
their respective spouses.
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