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assets that they transferred to each such partnership, they did
not receive adequate and full consideration for the assets trans-
ferred. Respondent’s argument in effect reads out of section
2036(a) the exception for “a bona fide sale for an adequate and
full consideration in money or money’s worth” in any case where
there is a bona fide, arm’s-length transfer of property to a
business entity (e.g., a partnership or a corporation) for which
the transferor receives an interest in such entity (e.g., a
partnership interest or stock) that is proportionate to the fair
market value of the property transferred to such entity and the
determination of the value of such an interest takes into account
appropriate discounts. We reject such an argument by respondent
that reads out of section 2036(a) the exception that Congress
expressly prescribed when it enacted that statute.
Respondent’s argument about the discounted values of the
partnership interests at issue also ignores the fact that each of
the Five Partnerships was created, funded, and operated as a
joint enterprise for profit for the management of its assets in
which there was a genuine pooling of property and services. We
have found that, when the partners of each of the Five Partner-
ships formed and funded each such partnership, they contemplated
and intended that each such partnership operate as a joint enter-
prise for profit for the management of its assets and that the
children contribute services in providing such management in the
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