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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,
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