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Partnership Interest. Each agreement provided that upon the death
of the later to die of the couple, CCF had the right to require
the trustee to buy CCF’s entire limited partnership interest.
Similarly, the trust could require CCF to sell its interest to the
trustee. CCF or the trust could exercise the right to buy or sell
within “sixty * * * days from the date the * * * [trust] collects
the death benefits” from a specified life insurance policy. It
was intended that the sale or purchase transaction be funded by a
life insurance policy.
Sometime later, Attorney Kelley left the United States, and
petitioners hired Attorney Frederick Meyer (Attorney Meyer).
Attorney Meyer conducted a review of petitioners’ documents,
including wills, family limited partnerships, and insurance
trusts, and he discovered what he considered to be inadequacies.
Attorney Meyer believed that the partnership agreements should
reflect a fiduciary duty to the charity and an obligation to share
cashflow with the charity. Edward Kramer (Mr. Kramer),
petitioners’ certified public accountant (C.P.A.), and Rance did
not believe this was necessary but reluctantly agreed to make the
changes. In 1997 the limited partnership agreements were revised
to accommodate the recommended changes. Petitioners did not rely
on Attorney Meyer with respect to valuation questions. They
relied on Mr. Kramer to take care of valuing the partnership
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Last modified: March 27, 2008