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According to petitioner, the decedent "made a direct
transfer of his voting rights to his sons"; he "did not
* * * transfer his voting shares to HBC for less than
adequate and full consideration in money or money's worth".
Therefore, according to petitioner, "respondents [sic]
reliance on �2512(b) and Treas. Reg. �2511-1(h)(1) [sic]
has no basis in fact or law, makes no sense, and is a
totally unreasonable and unrealistic approach to this
case."
We also reject this argument. First, there is nothing
in section 2512 or the cases decided thereunder to suggest
that section 2512(a) applies to "direct gifts" in which the
donor receives nothing in return or receives some part of
the gift, and section 2512(b) applies to other gifts in
which the donor receives back property rights that are
different from, or in addition to, the donor's property
rights in the gift. Section 2512(a) is a general provision
dealing with "gifts" that are "made in property". It
provides that the value of the property on the date of the
gift shall be considered the amount of the gift. Sec.
2512(a). The statute provides no definition of the term
"gift", but, as noted above, Congress intended to use the
term in its broadest and most comprehensive sense.
Commissioner v. Wemyss, 324 U.S. at 306; H. Rept. 708,
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