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trust in which the decedent retains only a life interest, the
adequacy of the consideration must be determined by comparing the
value of the consideration received with the total value of the
property the decedent transferred to the trust rather than with
just the remainder interest. Id. at 259-260. Indeed,
petitioner's argument is no different from contending that the
value of the retained life estate should be regarded as part of
the consideration received for the transfer, an argument this
Court has specifically rejected. Estate of Glen v. Commissioner,
45 T.C. 323, 343 (1966).
The same issue was presented in United States v. Past,
supra, where the decedent and her husband transferred their
community property to a trust in which the decedent received an
income interest for life. The transfer was pursuant to a divorce
settlement. Citing this Court's opinion in Estate of Gregory v.
Commissioner, supra, the Court of Appeals for the Ninth Circuit
rejected the argument that the decedent's transfer to the trust
was excepted from section 2036(a) as a bona fide sale for
adequate and full consideration. The court held that the
consideration received by the decedent had to be measured against
the total value of the property that she contributed to the
trust, rather than the value of the remainder interest in the
property that she contributed. Given that the decedent
transferred $243,989 in property to the trust in return for a
life estate worth approximately $143,346, the Court of Appeals
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