Estate of Webster E. Kelley, Deceased, John R. Louden and Patricia L. Louden, Personal Representatives - Page 2
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US Tax Court > 2005 > Estate of Webster E. Kelley, Deceased, John R. Louden and Patricia L. Louden, Personal Representatives - Page 2
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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
John R. Louden and Patricia L. Louden (the Loudens), personal
representatives of the estate, resided in Plano, Texas, at the
time the petition was filed. Decedent resided in Plano, Texas,
at the time of his death.
Decedent and his predeceased wife had one child, Patricia L.
Louden. Patricia L. Louden is married to John R. Louden, and
they have four children.
On April 6, 1999, decedent, Patricia L. Louden, and John R.
Louden organized Kelley-Louden Business Properties, LLC (KLBP
LLC), and Kelley-Louden, Ltd., a Texas limited partnership
(KLLP). Between June 6 and September 11, 1999, decedent
contributed $1,101,475 cash and certificates of deposit to KLLP.
On September 13, 1999, the Loudens contributed $50,000 cash to
At the time of decedent’s death, December 8, 1999, decedent
owned the following interests, the values of which are at issue
in this case:
KLBP LLC 33.33 percent
KLLP 94.83 percent
The Loudens owned the remaining two-thirds interest in KLBP LLC.
The Loudens also owned a 4.17-percent interest in KLLP. KLBP LLC
owned the remaining 1-percent interest of KLLP which is the only
asset of KLBP LLC. Therefore, we are valuing decedent’s
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