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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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