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decedent created a trust for the benefit of his wife and, at the
same time, his wife created a trust of equal value for his
benefit. The trusts had identical terms granting the other
spouse a life estate with the remainder to their children. The
Supreme Court applied the reciprocal trust doctrine which
requires that where two settlors simultaneously create trusts
with the same provisions and with similar property for the
benefit of each other, each settlor will be considered the
creator of the trust that is in form created by the other. See
id. The Supreme Court clarified that subjective intent of the
settlors is irrelevant and held the doctrine applies if the two
trusts: (1) Are interrelated, and (2) leave the settlors in
approximately the same economic position as they would have been
in had they created trusts naming themselves as beneficiaries.
See id.; Estate of Bischoff v. Commissioner, 69 T.C. 32 (1977).
This Court and other courts have applied the principles of
the reciprocal trust doctrine to gift tax cases under facts
similar to those of this case, see, e.g., Schultz v. United
States, 493 F.2d 1225 (4th Cir. 1974); Furst v. Commissioner,
supra, and we apply those principles herein. The gifts to the
nieces and nephews are interrelated. They are identical in type
and amount and were executed at the same time. Indeed, the gifts
were all part of a plan designed and carried out by petitioners
as a group. It is clear that the purpose of the plan was for
each married couple to benefit their own children. It is also
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