The Facts: (1) In 2002 myself and 3 other investors purchased a commercial building in Los Angeles, each buying a 25% ownership interest as Tenants in Common. (2) In 2003 I formed a Texas limited partnership. I have a 99.5% interest as a limited partner, and the general partner is a Texas corporation with a 0.5% interest. I own 100% of the shareholding of the general partner and am the sole officer and sole director. (3) In 2003 I set up a revocable Grantor Trust with myself as the sole trustee and the Trust Deed naming the limited partnership as the sole Trustee; (4) In 2003 my 25% ownership interest in the commercial property in Los Angeles was transferred to the limited partnership by means of a Grant Deed. The Grant Deed named the limited partnership as the Grantee, but did not specify the partnerships capacity or role as the Trustee of the trust. (5) The idea was for the partnership to only hold legal title to the while I operated the property and collected the rental income.
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