Estate of Mario E. Bosca, Deceased, Marie A. Baker Formerly Marie A. Bosca, Executor - Page 26

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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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