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partnership in 1984, legal title would vest in the limited
partnership but beneficial ownership of the timber, pecan
orchards, and other growing crops would remain with the
contributing limited partners individually. The undisputed
evidence shows that the parties consistently treated their
property interests as conforming to this mutual understanding.
The limited partnership never conducted any business with regard
to the timber, pecans, or other crops. Instead, after
transferring his property to the limited partnership, Mr. Forbes
continued to conduct his farming and timber business on the land
he previously held, received all income therefrom, and reported
all related income and deductions on his individual income tax
returns. Similarly, Walter and Betty continued to receive and
report individually all income from their farming and timber
business on the land they had contributed to the limited
partnership, creating the general partnership to conduct this
business.
After Mr. Forbes’ death, his executors conveyed to the QTIP
trust, and the QTIP trustee immediately reconveyed to Walter and
Betty, for consideration that respondent now concedes was full
and adequate, the assets of Mr. Forbes’ sole proprietorship. The
general bills of sale by which these conveyances were
accomplished expressly indicate that the conveyances included
“All growing crops and timber on land owned by” the limited
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