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disavow the form of, and previous tax reporting relating to, a
transaction. We hold that petitioner may not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time the petitions in these cases were filed, James E.
Corbett, Executor, resided in Akron, Ohio. James E. Corbett died
on March 28, 1995. Michael A. Sweeney, the duly appointed and
acting Administrator of the Estate of Hilda F. Corbett, and the
Estate of Hilda F. Corbett have mailing addresses in Akron, Ohio.
Hilda F. Corbett was married to James E. Corbett during all
relevant periods until her death in 1992. James and Hilda’s son,
David, was married to Billie Jean Corbett during all relevant
periods. In May 1974, David and Billie Jean purchased a house
located at 2424 West Market Street in Akron, Ohio (the House),
for $68,000.
During 1986, David and Billie Jean experienced financial
difficulties. As of March 20, 1986, the House was subject to
mortgages of approximately $68,000, and David and Billie Jean
owed approximately $4,000 in back taxes. David asked his father,
James, for $72,000 to pay off these debts.
James agreed to give David $72,000 on the condition that
David transfer to James and Hilda the title to the House. David
agreed to do so. On March 20, 1986, David and Billie Jean
transferred the House in fee simple to James and Hilda by
survivorship deed for $72,000. The transfer was reported in this
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