(before death, the decedent had begun the process of creating a family limited partnership (FLP), but failed to finalize it and transfer community property bonds (worth $300 million) to the FLP before death; decedent died on May 15, 2000, and estate filed Form 706 and paid $147 million in federal estate tax in February of 2001; tax counsel later learned of TX caselaw supporting discounts for FLP’s created and funded post-death and completed formation and funding of FLP that would make the FLP be deemed to be in existence before decedent’s death; as such, estate would lack sufficient liquid assets to pay estate tax; thus, estate tax payment restructured as loan from FLP with associated interest; refund claim filed due to valuation discount claim as result of FLP and estate claimed deduction for interest on loan; trial court ruled for estate based on TX law and appellate court affirmed; under TX law, intent of asset owner to make an asset partnership property determined property ownership with respect to initial partnership capitalization – title to property passed to FLP contemporaneous with its formation; discount upheld as was deduction for loan interest as an administrative expense).