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South Property. By substantially identical quitclaim deed, the
limited partnership conveyed to Walter and the QTIP trustee
undivided 58-percent and 42-percent interests, respectively, in
all of the limited partnership’s “right, title, and interest” to
the North Property.
In a letter dated October 7, 1988, Walter and Betty
confirmed to the QTIP trustee the terms of the termination
agreement. The letter states that in consideration of the QTIP
trustee’s agreement that Betty shall have “the use of the entire
South Property” and that Walter shall have “the use of the entire
North Property”, Betty and Walter each agree to pay any and all
ad valorem taxes with respect to their respective parcels, for so
long as the QTIP trustee should own any right, title, or interest
in their respective parcels.
Property Held by the QTIP Trust at Decedent’s Death
On December 26, 1993, the date of decedent’s death, the QTIP
trust held a 42-percent undivided interest in the South Property,
a 42.9-percent interest6 in the North Property, and two
6 After 1988, in an isolated transaction between the QTIP
trustee and Walter, the QTIP trust’s interest in the North
Property was increased to 42.9 percent and Walter’s interest in
the North Property was decreased to 57.1 percent.
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