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pursuant to an arrangement with the donor, would be in a "net
gift" transaction. Petitioners are liable as transferees for the
amount of property they received by gift because the donor did
not satisfy her primary obligation for the gift tax owed.
Had a "net gift" been made, petitioners would have paid the
resulting gift tax and the amount of the gift would have been
reduced accordingly. However, if the donor had not paid the full
amount of gift tax owed for that period, petitioners still would
remain liable as transferees up to the full amount of the gift
pursuant to section 6324(b). See LaFortane v. Commissioner, 29
T.C. 479, 489 (1957), affd. 263 F.2d 186, 194 (10th Cir. 1958).
The end result is that petitioners could be required to pay the
full value of the property received. A portion would be paid as
tax (the gift tax paid for the donor as consideration for the
"net gift"), and a portion would be paid to satisfy their
transferee liability, up to the full value of the gift received.
What petitioners argue for here is a result better than what
they could receive had a net gift been made. In essence, what
petitioners argue is that any amount they now are required to pay
should "purchase" a portion of the property they received,
ultimately leaving them liable for less than the full value of
what was transferred to them. Rev. Rul. 75-72, supra, provides
no support for such an argument. Petitioners' liability herein
is their personal liability to the Government, measured by what
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