Keller, et al. v. United States, No. V-02-62, 2009 U.S. Dist. LEXIS 73789 (S.D. Tex. Aug. 20, 2009)

(family limited partnership fully funded under state (Texas) law prior to decedent's death - immaterial that record title to property not transferred prior to death and decedent contractually obligated to fund general partner interest before death; decedent intended to transfer property to FLP at time she signed the FLP agreement; FLP formed for legitimate business reasons and transfer was for full and adequate consideration; estate entitled to refund of estate tax).