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F. Management of the Partnership Assets
Decedent controlled and managed, or allowed the coowners to
control and manage, the partnership assets in the same manner
both before and after he transferred them to the partnership. He
used the same brokers and managers before and after he
transferred the property. No one except decedent signed
partnership checks and documents. Welch managed the Kleberg
County property before and after October 22, 1993, and August 21,
1994. The executors for the Estate of Jessie Dennett managed the
Cameron County property before and after October 22, 1993, and
August 21, 1994. Decedent’s relationship to the partnership
assets did not change when he conveyed them to the trust and
partnership.
Hannah’s firm made adjusting entries in the partnership’s
accounting records in an attempt to classify items of income and
expense between decedent and the partnership. The difference
between cash on hand in the partnership account and the amount in
the general journal was $8,116 in 1993 and $13,507 in 1994.
Hannah’s firm assumed that these were the amounts of decedent’s
personal expenses that the partnership paid in those years.
5(...continued)
under sec. 2036(a), decedent’s gross estate includes the assets
that he conveyed to the trust and partnership.
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