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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.
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