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they received. What they pay is not consideration for what they
received as in the case of a net gift.
Petitioners' theory would allow them to keep a portion of
the property received from the donor at the expense of the
Treasury. Such a result is contrary to section 6324(b). See
Moore v. Commissioner, supra. Petitioners are liable for the
full value of the property transferred, without any reduction.
Decision will be entered
for respondent.
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Last modified: May 25, 2011