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property, leaving no remainder for the children. See Hudspeth v.
Hudspeth, 756 S.W.2d 29, 31 (Tex. App. 1988) (life tenant may
destroy any contingent interests held by remaindermen if testator
expressly gives life tenant power to completely dispose of
corpus); Calvert v. Thompson, 339 S.W.2d 685 (Tex. App. 1960)
(same). No document shows that decedent transferred only a life
interest in any asset to the trust or partnership.
We conclude that decedent owned and gave to the trust and
partnership during his lifetime all of the interests in the
Cameron, San Patricio, Nueces, and Kleberg Counties property that
had belonged to Mrs. Reichardt when she died.9 Thus, those
property interests are subject to section 2036.
5. Conclusion
We conclude that section 2036(a) applies to all of the
property that decedent transferred to the partnership.
C. Amount Included in Decedent’s Estate Under Section 2036(a)
To decide the amount included in decedent’s estate under
section 2036(a), we must decide the value on the date of
decedent’s death of the property that decedent transferred to the
partnership. James R. Parks (Parks), petitioner’s expert who
9 Decedent’s life interest in the Cameron and San Patricio
Counties property included the power to convey that property to
the partnership. Decedent did so even though that property
remained in the name of the Estate of Jessie Dennett. See Logan
v. Logan, 156 S.W.2d 507, 512 (Tex. 1941); King v. Evans, 791
S.W.2d 531 (Tex. App. 1990).
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