Estate of Eugene E. Stone, III, Deceased, C. Rivers Stone, E.E. Stone, IV, Mary Stone Fraser & Rosalie Stone Morris, Co-Personal Representatives - Page 22

                                       - 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).                                                                    




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