- 20 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Last modified: May 25, 2011