| http://www.w3.org/ns/prov#value | - The position taken by taxpayers (i.e., those operating in non-corporate form) and other stakeholders was that, so long as the transfer of funds or property constitutes a contribution to capital under the criteria established in case law (such as the Chicago, Burlington factors set out above), it does not matter whether the entity receiving the funds or property is a partnership or other non-corpor
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