-17-
Hemholz, 296 U.S. 93 (1935); Burnet v. Guggenheim, 288 U.S. 280
(1933); Dodge v. Commissioner, T.C. Memo. 1968-238. It follows
that, inasmuch as decedent had, during 1984, the power to revest
title in herself as to six-ninths of the property, six-ninths of
decedent's transfer in 1984 was illusory and therefore did not
have the necessary degree of completeness to be recognized for
Federal tax purposes. Burnet v. Guggenheim, supra; sec. 25.2511-
2(c), Gift Tax Regs.
We are satisfied, as our findings of fact show, that
decedent transferred three-ninths of her interest in the
Weinstock Residence in 1984. With respect to 1985 and 1986, the
situation is very similar. Deeds of three-ninths interests for
1985 and 1986 were submitted in evidence. Accordingly, we find
that in 1985, the donees were given complete ownership of an
additional three-ninths of decedent's interest in the property,
and decedent had the right to revest title in herself as to the
remaining three-ninths defeasible interest. Cf. Dodge v.
Commissioner, T.C. Memo. 1968-238 (Court could not find taxpayer
transferred his retained interest in the property where he
offered no persuasive evidence of the transfer). Thus, after her
transfer in 1985, only three-ninths of decedent's transfer in
1984 was illusory and did not have the necessary degree of
completeness to be recognized for Federal tax purposes. Burnet
v. Guggenheim, supra; sec. 25.2511-2(c), Gift Tax Regs.
Finally, in 1986 decedent deeded the last of her interest in
the property to her children, and decedent's right to revest
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