Estate of Hilde E. Erickson, Deceased, Donor, Karen E. Lange, Personal Representative - Page 9




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               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