Estate of Sylvia Gore, Donor, Deceased, Pamela Powell, Personal Representative - Page 12




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          Although Ms. Bowers had consulted decedent about forming GFLP,              
          decedent did not participate in its formation.  On December 26,             
          1996, the secretary of state for the State of Oklahoma issued a             
          formal certificate.9                                                        
               On December 26, 1996, Ms. Powell and Mr. Gore executed the             
          GFLP Partnership Agreement (partnership agreement).  The                    
          partnership agreement provided that GFLP was formed for                     
          investment purposes and that profits and losses would be                    
          allocated in proportion to the capital accounts of the partners.            
          With regard to initial capital contributions to GFLP, the                   
          partnership agreement provided, in part, the following:                     
               Each Partner shall make an initial contribution to the                 
               capital of the Partnership, simultaneously with the                    
               execution of this Agreement, in the amount shown on                    
               Schedule A.  In consideration, each Partner shall be                   
               issued such number of units of Partnership interest                    
               (“Partnership Units”) as is indicated on Schedule A,                   
               consisting of the number of units of General                           
               Partnership interest (each a “General Partnership                      
               Unit”) and units of Limited Partnership interest (each                 
               a “Limited Partnership Unit”) shown on Schedule A.                     
               Each Partnership Unit shall represent equivalent                       
               economic interests in the Partnership.                                 
          Schedule A to the partnership agreement named only Mr. Gore and             
          Ms. Powell as general partners and did not list the names of any            
          limited partners.  Schedule A showed that Mr. Gore and Ms. Powell           
          had contributed $500 each for a general partnership unit.  In               



               9Respondent does not dispute that GFLP is a valid entity               
          under Oklahoma law.                                                         





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