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for the family farm with a value of $15 per hour; (2) Mrs.
Klippel performed not more than 10 hours of services per week
with a value of $8 per hour; (3) James O. Hendrickson performed
no material services for the family farm; and (4) the value of
the services performed by the children for the family farm during
1979-93 did not exceed $172,500.
In this case the value of the part-time services performed
by the children is therefore far less than the $913,200
assertedly contributed by decedent to the partnership or the
$793,000 excess of decedent's contributions over 50 percent of
the partnership's aggregate cash needs. This imbalance between
the capital contributed by the parent and the services
contributed by the children suggests that our analysis in Gross
v. Commissioner, 7 T.C. 837 (1946) (formation of family
partnership created gift, even though children agreed to
contribute substantial services, where partnership's income was
primarily attributable to parent's contributed capital), applies
to this case, rather than our analysis in Fischer.
Moreover, in this case the relationship between the services
allegedly performed by the children and the interests they
allegedly received in the farm partnership serves as further
proof that if the farm partnership existed, any transfers by
decedent to that partnership were neither at arm's length nor
free from donative intent. The value of the services performed
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