- 110 - each of the Five Partnerships held respective partnership inter- ests in each such partnership that were proportionate to the fair market value of the assets that such partners respectively trans- ferred to each such partnership; (2) the respective assets that the partners of each such partnership transferred to each such partnership were properly credited to the respective capital accounts of such partners; and (3) upon the termination or disso- lution of each of the Five Partnerships, the partners of each such partnership were entitled to distributions from each such partnership in amounts equal to their respective capital ac- counts. Under the circumstances presented in the instant cases, we find that Mr. Stone and Ms. Stone, as well as the other part- ners of each of the Five Partnerships, received in exchange for their respective transfers of assets to each such partnership respective partnership interests in each such partnership that were adequate and full equivalents reducible to a money value. See secs. 20.2036-1(a), 20.2043-1(a), Estate Tax Regs.; see also Estate of Goetchius, 17 T.C. at 503. Respondent nonetheless argues that, because Mr. Stone and Ms. Stone received respective partnership interests in each of the Five Partnerships the value of which, taking into account appropriate discounts, was less than the value of the respective 76(...continued) 2036(a).Page: Previous 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 Next
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