- 22 -                                         
               According to the "accounting" of Garry's estate introduced              
          by petitioner at trial, the payments Garry's estate received from            
          HEI during 1979-93 totaled approximately $411,000.  Many of these            
          payments were referred to as interest in the accounting.                     
               The payments Garry's estate received from HEI during 1979-93            
          were therefore less than the amount of interest owed by HEI                  
          during that period.                                                          
               HEI did not pay off the $359,534 receivable reported on the             
          estate tax return of Garry's estate.                                         
               The $166,500 HEI receivable reported on petitioner's estate             
          tax return is part of the same receivable reported on Garry's                
          estate tax return.                                                           
               Garry's estate did not use any of decedent's investment                 
          income to acquire the $166,500 receivable from HEI (or to acquire            
          any other receivable from HEI during 1979-93).                               
          Children's Performance of Services for Family Farm                           
               During 1979-93, Donald Hendrickson and Mrs. Klippel each                
          performed not more than 10 hours per week of services relating to            
          the family farm, with values of $15 per hour and $8 per hour,                
          respectively.  James O. Hendrickson did not perform any material             
          services relating to the family farm during that period.                     
               The aggregate value of the services performed by the                    
          children relating to the family farm during 1979-93 therefore did            
          not exceed $172,500 (i.e., 10 hours per week, times 50 weeks per             
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