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orchestrator of its implementation. We are aware that the
parties have stipulated that 'Because of Julian's tax, financial,
and business expertise, Meredith and Nancy generally consult with
Julian about all major or significant financial transactions.'
But such a general description lacks the quality necessary to
support the conclusion that there was meaningful advance
consultation and exercise of independent judgment by Nancy and
Meredith in respect of the specific transactions involved herein,
to say nothing of the fact that the stipulation does not include
any reference to Permenter. Moreover, we note that Exhibits A
executed by petitioner and Nancy, Meredith, or Permenter were
uniformly dated the same day as the confirmations from Prudential
Bache. The amounts of funds provided from time to time by
petitioner to Nancy, Meredith, and Permenter were, within
pennies, equal to the amounts of the checks they issued to
Prudential Bache; by way of contrast, the separate funds of the
trust in Gordon v. Commissioner, supra, were used albeit to a
minor extent. The time spans between confirmation, payment, and
closing dates reflected in Exhibit 1 to this opinion are such as
to indicate that neither Nancy, Meredith, nor Permenter had any
meaningful opportunity or desire to exercise dominion and control
over the funds and elect not to participate in the purchases.
In short, we are satisfied that, on the basis of the record
as a whole, petitioner, like the taxpayer in Gordon v.
Commissioner, supra, acquired the entire ownership in the bonds
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