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D. The Gifts
1. Nature and Timing of the Gifts; Consequences
We find that Parker made gifts to the daughters no later
than January 26, 1980, of some or all of his rights under the
earnest money contracts. The rights of the daughters in the
property subject to the earnest money contracts (the Northgate
Forest property) were contributed to the joint venture in
consideration of a 40-percent interest in the joint venture, as
reflected in the January 8 writing. The $2 million notes
received by the daughters were in consideration of their
interests in the joint venture. The daughters owned the
$2 million notes at the time of their redemption in 1985 and,
therefore, are taxable on the proceeds of those notes. Parker is
not taxable on those proceeds.
2. Intent to Make a Gift
"[T]he intent of the donor * * * is the principal issue in
determining whether a gift has been made." Id. at 344.
There is substantial evidence supporting the conclusion
that, sometime before the joint venture was formed on January 26,
1980, Parker formed the intent to make gifts to the daughters,
and we so find. Parker told both Nathan and Thoner that the
daughters had some part of the Northgate Forest property deal.
Bradish certainly understood that, as evidenced by the January 8
writing. Indeed, Bradish dictated to Mrs. Bradish the terms of
the January 8 writing. At or about the time of the January 8
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