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partnerships, coupled with petitioners’ transfers of limited
partnership interests to their children (or in trust therefor),
constitute indirect gifts of the stock to the children (or to the
trusts) within the meaning of section 2511.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioners resided in Lake St. Louis, Missouri, at the time that
they filed their petition in this case.
General Background
Petitioners have three minor children, Mark R. Senda,
Janell N. Senda, and Ross J. Senda (collectively, the children).
On May 29, 1996, Mark W. Senda (petitioner) attended a
seminar in Chicago, Illinois, on tax planning regarding the tax
benefits of forming a family limited partnership (FLP). The
seminar, Executive Tax/Financial Planning Seminar, was sponsored
by Arthur Andersen, LLP, and Fraser Stryker Meusey Olson Boyer &
Bloch, P.C., an Omaha, Nebraska, law firm. On December 30, 1996,
petitioners formed, but did not fund, an FLP under Illinois law.
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