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Formation of McCord Interests, Ltd., L.L.P.
McCord Interests, Ltd., L.L.P. (MIL or the partnership), is
a Texas limited partnership formed on June 30, 1995, among
petitioners, as class A limited partners; petitioners, the
children, and another partnership formed by the children (McCord
Brothers Partnership), as class B limited partners; and the
children as general partners (all such partners being hereafter
referred to as the initial MIL partners).
On formation, as well as on the date of the assignments in
question, the principal assets of MIL were stocks, bonds, real
estate, oil and gas investments, and other closely held business
interests. On the date of the assignments, approximately 65
percent and 30 percent of the partnership’s assets consisted of
marketable securities and interests in real estate limited
partnerships, respectively. The remaining approximately 5
percent of the partnership’s assets consisted of direct real
estate holdings, interests in oil and gas partnerships, and other
oil and gas interests.
In mid-October 1995, the MIL partnership agreement was
amended and restated, effective as of November 1, 1995 (such
amended and restated partnership agreement being referred to
hereafter as, simply, the partnership agreement). Attached to
the partnership agreement is a schedule setting forth the capital
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Last modified: May 25, 2011