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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
children?
A How did I transfer? I’m not certain what the
right, what you’re looking for here.
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