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          circumstances mentioned above.  Petitioners counter that they did           
          not amend the formula when they amended the agreements for other            
          reasons because they believed that the agreements produced a fair           
          and reasonable price.  On the contrary, we believe that                     
          petitioners did not alter the formula price because the sons                
          would benefit (taxwise and pricewise) from leaving in place a               
          formula transfer price that was as low as possible.                         
                         h. Business Arrangements With True Children                  
                             Fulfilled Dave True’s Testamentary Intent                
               Dave True’s business arrangements with his children                    
          fulfilled his testamentary intent, as evidenced by his will and             
          ancillary estate planning documents.  At his death, Dave True’s             
          estate plan provided equally for his children, except Tamma                 
          Hatten.  Dave and Jean True amended their estate planning                   
          documents to delete any specific provisions for Tamma Hatten and            
          her family after her withdrawal from the family businesses.  The            
          advancement language in Dave True’s appointment document                    
          explained that Tamma Hatten’s “potential inheritance” had been              
          fully satisfied when his daughter severed her financial ties with           
          the True companies.                                                         
               Since the 1970's, each of the True sons has managed one or             
          more of the True companies.  Hank True assumed responsibility for           
          the oil and gas marketing, pipeline, and environmental cleanup              
          businesses; Diemer True managed the trucking and tool supply                
          companies; and David L. True ran the ranching and drilling                  
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