113 T.C. No. 30
UNITED STATES TAX COURT
BAINE P. AND MILDRED C. KERR, DONORS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14449-98. Filed December 23, 1999.
In 1993, Ps and their children formed two family
limited partnerships (KFLP and KILP). The KFLP and KILP
partnership agreements contain identical restrictions on
liquidation of the partnerships. In June 1994, Ps
transferred limited partnership interests in KFLP and
KILP to the University of Texas (the university).
On Dec. 28, 1994, Ps created separate grantor
retained annuity trusts (GRAT’s). Ps each transferred a
44.535-percent class B limited partnership interest in
KFLP to their GRAT’s. The GRAT’s remainder interests
were intended to benefit Ps grandchildren through
generation-skipping trusts.
On Dec. 30, 1994, the university was admitted as a
limited partner of KILP. On Dec. 31, 1994 and 1995, Ps
transferred limited partnership interests in KILP to
their children.
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