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commingling of funds between the partnership and decedent. See,
e.g., Estate of Reichardt v. Commissioner, 114 T.C. at 155.
Gates testified that she tracked the financial statements and
kept the accounting books for the partnership exactly as she had
for Sea Shell. No changes were made until after decedent’s
death. This testimony does not explain how the personal
residence was not a partnership asset. Instead, it demonstrates
the estate’s complete disregard for the formalities of financial
statements.
Based on the record as a whole, we reject the estate’s
claims that the partnership agreement changed any real
relationship between Hillgren and decedent or that it changed
decedent’s interest in the properties.
3. Distributions From LKHP
The estate admits that decedent received all of the income
distributed from the partnership in the 5 months preceding her
death. The estate further admits that decedent was dependent on
the cashflow from the partnership for her living expenses. The
estate claims that, presumably, Hillgren would have received cash
distributions as well if decedent had remained alive through the
end of the year. In addition, the estate claims that there was
no history of disproportionate distributions because the 5 months
of partnership distributions was too short to create a pattern.
Respondent argues that there was an implied agreement, as
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