Walter R. Ripley, Donee-Transferee of Mildred M. Ripley, Donor, and Melynda H. Ripley, Donee-Transferee of Mildred M. Ripley, Donor - Page 20

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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