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the underpinnings of that question which we explored in detail in
Gordon v. Commissioner, supra, and Richard Hansen Land, Inc. v.
Commissioner, supra. We think it important, however, to
recognize, as we did in those cases, that the fact that tax
reasons generated the choice of the structure used is not, in and
of itself, sufficient to require us to sustain respondent.
Against the foregoing background, we proceed to examine the
various elements involved herein, upon which the base resolution
of the ultimate factual question, i.e., were there separate
purchases of a life interest by petitioner and of the remaining
interests by the other parties or was there a purchase of the
entire ownership of the bonds by petitioner followed by a gift of
the interests in the bonds remaining after petitioner's retained
life estate. The burden of proof is on petitioner, Rule 142(a),
and that burden is not lessened because this is a fully
stipulated case. Borchers v. Commissioner, 95 T.C. 82, 91
(1990), affd. 943 F.2d 22 (8th Cir. 1991).
Some preliminary observations are in order. First, we
recognize, as we did in Gordon v. Commissioner, supra, that the
holders of the remaining interests were related to petitioner,
i.e., daughters, or closely identified with petitioner, i.e.,
petitioner's longtime secretary.6 While such relationships are
6 While Permenter was not "related" to petitioner in the same
way as his daughters, see secs. 167(e)(5)(B) and 267, we are
satisfied that, on the basis of the record herein, her
(continued...)
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