Estate of Charles E. Reichardt - Page 9




                                        - 9 -                                         
          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.                              





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011