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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).
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