-25- before decedent’s death the repayment of any of the funds reflected in either note. Nor was there any stated security or collateral for any repayment of the funds reflected in either note. During her life, decedent never repaid any of the principal or interest reflected in note 1 or note 2. Nor did decedent have the ability to repay those amounts unless she sold (or the LRFLP redeemed) her interest in the LRFLP for a price greater than those amounts. As discussed below, decedent’s limited partnership interest in the LRFLP was redeemed after she died, and her estate paid all of the amounts shown as due in the notes (inclusive of principal and interest) through a reduction of the proceeds that the estate received in the redemption. 11. Gifts of the LRFLP Interests Between October 11, 1996, and January 7, 2000, decedent’s daughter (as decedent’s attorney-in-fact) gave decedent’s descendants a total of 64.0012 percent of the limited partnership interest in the LRFLP. The specifics of these gifts were as follows:14 14 As of Oct. 11, 1996, the number of decedent’s descendants had increased to 19 on account of the births of Zachary Silver and Julia Anne Levens and the apparent marriage of Daniel and Dana Silver. In each of the years from 1997 through 2000, decedent’s daughter (as decedent’s attorney-in-fact) gave cash or a limited partnership interest in the LRFLP to 18 of the 19 descendants. Dana Silver received a gift ($10,000 cash) only in 1997. The record does not indicate whether Dana Silver remained (continued...)Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011