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is closed; (3) whether restrictions on liquidation of the
partnerships should be disregarded for gift tax valuation
purposes pursuant to section 2704(b); and (4) the fair market
value of interests in the partnerships transferred by gift after
formation. Unless otherwise indicated, all section references
are to the Internal Revenue Code in effect on the date of the
transfers, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. W.W.
Jones II (decedent), resided in Corpus Christi, Texas, at the
time the petition in this case was filed. Decedent subsequently
died on December 17, 1998, and a motion to substitute the estate
of W.W. Jones II, deceased, A.C. Jones IV, independent executor,
as petitioner was granted. The place of probate of decedent’s
estate is Nueces County, Texas. At the time of his appointment
as executor, A.C. Jones IV (A.C. Jones), also resided in Nueces
County, Texas.
For most of his life, decedent worked as a cattle rancher in
southwest Texas. Decedent had one son, A.C. Jones, and four
daughters, Elizabeth Jones, Susan Jones Miller, Kathleen Jones
Avery, and Lorine Jones Booth.
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