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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              
                                  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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