1. Countess Aether, now a California resident, owns a 60% interest in the Gore General Partnership which only does business in California.
2. Countess Aether has a basis of $400,000 and a fair market value of $2,000,000 in the partnership. Her share of partnership liabilities is $1,000,000 which are included in his $400,000 basis calculation.
3. Countess Aether is nearing retirement age, which is not very young in her profession, and has decided to give away her partnership interest on June 15th.
4. The partnership's year ends on June 30th as it has a 50% plus capital interest owner (Gaia Corporation).
5. Countess Aether intends to give half of her interest to her son, Uranus and half to the Chapman University.
6. Countess Aether is 84 years old and in less than robust health as a life time smoker. Her net assets, exclusive of his interest in the partnership, exceed $18,000,000. She is single, but dating a young man, Phanes, who is 30 years old, who she loves and believes loves her.