(decedent formed FLP and moved into assisted living facility simultaneously; two years later, decedent funded partnership with personal assets and trust subsequently dissolved; while decedent sole owner of FLP, two children listed as general partners even though contributing nothing to FLP; FLP loaned funds to decedent's children with such loans documented but with no terms except to establish interest payments; some assets kept out of FLP for decedent's care; upon decedent's death, 40% discount claimed on FLP assets; court held that no discounts allowable because decedent owned 100 percent of FLP interests and FLP agreement said that FLP would dissolve upon one partner acquiring interests of all others; decedent owned all assets individually and assets includible in decedent's estate at full FMV).