- 40 - contribute their shares of the investment income of Garry's estate to the partnership, to be used as necessary to support the farming activities. Petitioner further asserts that, as matters turned out, decedent's $913,200 of investment income was in fact contributed to the partnership to support the losses of the farm operations. As an initial response to petitioner’s argument, we note that there was no written partnership agreement among decedent and the children concerning the operation of the family farm. In addition, the record contains no Forms 1065 (or other partnership tax reporting forms) relating to the claimed family farm partnership--although at least three other pass-through entities in which decedent or the children had an ownership interest filed Federal income tax forms. We also note that petitioner's Federal estate tax return did not report, as one of the assets of decedent's estate, a partnership interest in the family farm. It also did not report as an asset any of the three bank accounts petitioner claims were used to conduct the business of the farm partnership. Moreover, with respect to any equipment of the partnership, petitioner's estate tax return reported less than $15,000 worth of farm equipment as assets of decedent's estate, all of which had been inherited by decedent from Garry in 1979. Furthermore, with respect to any income or loss of the claimed farm partnership,Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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