Baine P. and Mildred C. Kerr v. Commissioner

113 T.C. No. 30

UNITED STATES TAX COURT BAINE P. AND MILDRED C. KERR, DONORS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14449-98. Filed December 23, 1999. In 1993, Ps and their children formed two family limited partnerships (KFLP and KILP). The KFLP and KILP partnership agreements contain identical restrictions on liquidation of the partnerships. In June 1994, Ps transferred limited partnership interests in KFLP and KILP to the University of Texas (the university). On Dec. 28, 1994, Ps created separate grantor retained annuity trusts (GRAT’s). Ps each transferred…