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          was enhanced by the contributions of the taxpayer.  Accordingly,            
          we held that the transfers to the partnership were indirect gifts           
          by the taxpayer to his sons of undivided 25-percent interests in            
          the real property and stock.  Id. at 389.  The Court of Appeals             
          for the Eleventh Circuit affirmed our decision for the reasons              
          stated in our Opinion.                                                      
               Petitioners’ transfers of stock in the instant case are                
          similar to the transfer of property in Shepherd.  In both cases,            
          the value of the children’s partnership interests was enhanced by           
          their parents’ contributions to the partnerships.  Petitioners              
          attempt to distinguish Shepherd by referring to our statement in            
          that case that “not every capital contribution to a partnership             
          results in a gift to the other partners, particularly where the             
          contributing partner’s capital account is increased by the amount           
          of his contribution”.  Id. at 389.  Petitioners argue that, in              
          the instant case, petitioners’ capital accounts were increased by           
          the amount of their contributions.  Petitioners further argue               
          that, under Estate of Jones v. Commissioner, 116 T.C. 121 (2001),           
          it is irrelevant that the contributions of the stock to the                 
          partnerships and the transfers of the partnership interests to              
          the children occurred on the same day.                                      
               In Estate of Jones, the taxpayer contributed property to the           
          partnerships and received continuing limited partnership                    
          interests in return.  All of the contributions of property were             

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