- 14 -                                         
          properly reflected in the capital accounts of the taxpayer.  Id.            
          at 128.  In the instant case, however, it is unclear whether                
          petitioners’ contributions of stock were ever reflected in their            
          capital accounts.  On cross-examination, petitioner testified               
          with respect to SFLP I as follows:                                          
                    Q  And, at that same time, certainly the same day,                
               you transferred the partnership interests, limited                     
               partnership interests from yourself and Michele to the                 
               children, correct?                                                     
                    A  Yes, sir.                                                      
                    Q  And when did you do that?  On December 28?                     
                              *   *   *   *   *   *   *                               
                    A  Well, keep in mind that these things have been                 
               weeks in the making.  So the fact that they triggered                  
               at a particular day or on a particular day may or may                  
               not be relevant.                                                       
                    The fact that that happened during that day, I                    
               couldn’t tell you if it happened at 1:00, 3:00 or 5:00.                
               If that’s what you’re asking me.                                       
                    Q  That was what I was asking you.  The transfer                  
               of the limited partnership interests, how did that                     
               occur on December 28, 1998?                                            
                    A  How did that occur?  Tell me where you’re                      
               going.  I’m not sure.                                                  
                              *   *   *   *   *   *   *                               
                    Q  So how did you transfer it from yourself to the                
                    A  How did I transfer?  I’m not certain what the                  
               right, what you’re looking for here.                                   

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