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stock which, during the years at issue, were its sole asset.
Sometime after December 20, 1995, Rhett and Alice transferred into
Zerubbabel Limited Partnership (Zerubbabel) their 249.5 shares of
Beneco stock which, during the years at issue, were its sole
asset.
Christian Community Foundation (CCF), a section 501(c)(3)
charity for tax purposes, was incorporated in 1980 under the laws
of Colorado. On or about December 19, 1995, Attorney Kelley sent
a letter to CCF, enclosing a check for $1,000 and an Application
to Begin a Charitable Project. CCF set up the Zacchaeus
Foundation (Zacchaeus), a donor-advised fund, for petitioners and
assigned to it account No. 06022.
Attorney Kelley advised CCF that for 1995, Rance and LaRhea
would be contributing an FLP interest having a value of $350,000
and that Rhett and Alice and Zane and Shannon would each be
contributing an FLP interest having a value of $185,000. Attorney
Kelley further advised that petitioners would be making annual
gifts in amounts to be determined by their income for the
particular year. He further advised that all of the gifts of FLP
interests that were made to the project would be reacquired via
irrevocable life insurance trusts that were to be funded by life
insurance and that application had been made for the insurance.
In 1996, the irrevocable trust of each couple and CCF
executed a separate Agreement for the Purchase and Sale of Limited
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