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To reflect the foregoing,
Decision will be entered
for respondent.
29(...continued)
before us, we reject petitioners’ contention that Mr.
Stottlemeyer owned a 50-percent capital interest in Kildare Timmy
on Jan. 1, 1998. In this regard, we have found that (1) Mr.
Ramsburg and Mr. Stottlemeyer made cash capital contributions to
Kildare Timmy totaling around $1,336,459 and $282,187, respec-
tively, (2) in return for Mr. Stottlemeyer’s management services,
Mr. Stottlemeyer did not receive any salary from Kildare Timmy or
increases in his Kildare Timmy capital account, and (3) on Jan.
1, 1998, Kildare Timmy distributed all of its assets (i.e., the
racing and breeding horses, the stud rights, and the Kildare
Timmy bank account balance) to Mr. Ramsburg and distributed none
of its assets to Mr. Stottlemeyer.
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