-21-
Annuity (approximate value) 1,600/yr.
Social Security benefits (approximate value) 1,459/mo.
Jewelry, furniture, and other personal
property (approximate value) 11,000
Following the transfer of decedent’s assets to the LRFLP,
her retained assets were insufficient to pay her living expenses
and the cost of her formal gift-giving program. When the LRFLP
was formed, 8 of her then 17 descendants depended on an annual
cash gift from decedent of at least $10,000, and those 8
individuals did not want to receive a portion of decedent’s
limited partnership interest in lieu of cash. Decedent’s
daughter knew that she would have to withdraw money from the
LRFLP to give (on behalf of decedent) $80,000 to those family
members in 1997. Decedent’s daughter also knew that she would
have to withdraw more money to pay some of decedent’s living
expenses. Decedent’s daughter called Feldman in December 1996
and told him that she had to withdraw $80,000 from the LRFLP in
that month to make gifts in January 1997 and that she would have
to withdraw more funds in later years to pay decedent’s living
expenses for those later years. Feldman told decedent’s daughter
to consider any withdrawal from the LRFLP to be a loan to
decedent from the LRFLP. Decedent’s daughter did not discuss
with decedent’s son the making of any such loans by the LRFLP,
and decedent’s son was never involved in treating any amounts
withdrawn from the LRFLP as loans to decedent. Decedent’s
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