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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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