- 10 - Finally, petitioner relies heavily on cases involving what he claims to be analogous transactions, especially those dealing with gifts of stock to a charity followed by a redemption of such stock by the corporation. We dealt at some length with these cases and cases involving seemingly analogous situations in Gordon v. Commissioner, 85 T.C. at 327, and concluded that such cases "are sufficiently distinguishable in terms of their factual context and the issue involved so as not to furnish any significant guidance to our decision herein." We continue to adhere to that view. Petitioner attaches great significance to the fact that gift tax returns were filed in respect of all the funds provided by petitioner, whereas in Gordon v. Commissioner, supra, most of the transfers of funds by the taxpayer to the holder of the remainder interest were not reflected in any gift tax returns. We are not persuaded that this provides a significant basis for distinguishing Gordon. Such returns merely reflect the values of the gifts8 to the recipients which happen to coincide with the amounts of the funds transferred. Although the gift tax returns stated that the gifts were cash gifts, such self-serving labeling is not determinative and its impact is not significant in light 7(...continued) to the holder of the remainder but not used was a factor unfavorable to the taxpayer's position. 8 See supra note 3.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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