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Kerr children are financially independent. Petitioners have 13
grandchildren.
Petitioners both graduated from the University of Texas.
Baine P. Kerr (petitioner) also graduated from the University of
Texas Law School.
After serving in World War II, petitioner joined the law firm
of Baker & Botts in Houston, Texas, subsequently was admitted as a
partner, and ultimately managed the firm's corporate law
department.
Petitioner left Baker & Botts to serve in various executive
positions at Pennzoil Co. Between 1964 and 1994, petitioner served
on Pennzoil's board of directors and as president. In 1989, he
received a $10 million bonus for work that he had performed in a
lawsuit that Pennzoil had filed against Texaco.
S. Stacey Eastland (Eastland), an attorney at Baker & Botts,
advised petitioners on estate planning matters for many years.
Eastland has written extensively on the use of family limited
partnerships (and particularly transfers of assignee interests) as
an estate planning tool.4 In September 1993, Eastland proposed
that petitioners create two limited partnerships. Eastland advised
petitioners that the limited partnerships could be used as a source
4 See Eastland, Family Limited Partnerships: Non-Transfer
Tax Benefits, 10 Probate and Property (Mar./Apr. 1993); Eastland,
“The Art of Making Uncle Sam Your Assignee Instead Of Your Senior
Partner: The Use of Partnerships In Estate Planning”, SD 63 ALI-
ABA 1153 (May 1999).
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