Estate of Charles E. Reichardt - Page 8




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          decedent’s community property from Mrs. Reichardt's estate to the           
          trust.  On August 12, 1993, decedent, as trustee, conveyed the              
          Graham note from the trust to the partnership.                              
               On August 13, 1993, decedent transferred $32,871.78 from his           
          two personal accounts at Frost National Bank in San Antonio to a            
          new partnership account at that bank.  Decedent received at least           
          $20,540 of the $32,871.78 from rental income from property he had           
          transferred to the partnership.                                             
               The Estate of Jessie Dennett made no payments to Mrs.                  
          Reichardt’s estate or to decedent from rent receipts or property            
          sales distributions in 1993 and 1994 from any of the real                   
          property in Cameron County.  The Estate of Jessie Dennett paid              
          $30,000 to Mrs. Reichardt's estate on June 19, 1995, as its share           
          of the proceeds from the sale of some real property.  This amount           
          was deposited in the partnership’s bank account.                            
               Decedent lived at 214 Encino before and after he transferred           
          it to the trust and to the partnership.  He paid no rent to the             
          trust or the partnership to use that residence.                             
          E.   Decedent's Gift of Limited Partnership Interests to His                
               Children                                                               
               On October 22, 1993, decedent gave each of his children a              
          30.4-percent interest in the partnership.5                                  


               5  Petitioner contends that decedent’s children received               
          assignee interests.  We need not decide whether they received               
          limited partnership interests or assignee interests because,                
                                                             (continued...)           





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