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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...)
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