-9-
Finally, the limited partnership agreement also provided
that the credit trust would contribute a Florida condominium in
exchange for an 8.2-percent limited partnership interest. The
credit trust did not contribute any of the $1 million in
marketable securities it owned to the Partnership. Both Karen
and Sigrid were aware that there were no estate tax concerns
regarding the assets in the credit trust unlike the estate tax
concerns they had regarding Mrs. Erickson’s personal assets.
Instead, Karen and Sigrid would receive the credit trust assets
free of estate tax after Mrs. Erickson’s death. They thus opted
to leave the credit trust securities outside the Partnership.
Transfer of Assets to the Partnership
Although the limited partnership agreement contemplated that
the partners’ assets would be contributed to the Partnership
concurrently with the signing of the limited partnership
agreement, no transfers to the Partnership occurred upon
execution of the agreement.
Karen took care of some administrative matters first, such
as obtaining a certificate of limited partnership from the State
of Colorado and applying for an employer identification number.
The certificate of limited partnership listed a Snowmass Village,
Colorado, address for service of process, an address that had no
mail delivery.
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Last modified: November 10, 2007