Baine P. and Mildred C. Kerr - Page 12




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          the Mildred Caldwell and Baine Perkins Kerr Centennial                      
          Professorship in English History and Culture.  In 1988, petitioners         
          donated Pennzoil Co. stock valued at $433,687 to the university to          
          enhance the aforementioned endowment and to redesignate the                 
          professorship as a chair--the Mildred Caldwell and Baine Perkins            
          Kerr Centennial Chair in English History and Culture.                       
              On June 24, 1994, petitioners and a representative of the              
          university executed two documents entitled “Assignment of                   
          Partnership Interest”, which state that petitioners were                    
          transferring to the university one value unit of a class A limited          
          partnership interest in KFLP and nine value units of a class A              
          limited partnership interest in KILP.  The assignments state that           
          petitioners desired to assign a portion of their interests in KFLP          
          and KILP as more particularly described in schedule I thereto.              
          Schedule I to the assignments states in pertinent part: “The                
          Assigned Partnership Interest constituted a Class A Limited                 
          Partnership Interest in * * * [the partnerships] when owned by              
          Assignors, and when owned by Assignee shall constitute a Class A            
          Limited Partnership Interest in said partnership.”                          
               On December 30, 1994, the KILP partnership agreement was               
          amended to state that the university would be admitted as a class           
          A limited partner.                                                          
          Transfers to Grantor Retained Annuity Trusts                                
               On December 28, 1994, petitioner Baine P. Kerr created the             
          Baine P. Kerr 1994 Retained Annuity Trust under which he served as          




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