Larry L. Sather, Donor, et al. - Page 14




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          clear that the gifts in trust left each beneficiary (the nieces             
          and nephews), to the extent of mutual value, in the same position           
          as they would have been in had their parents given the property             
          directly to them.  In relation to one another, the nieces and               
          nephews all were left in the same economic position.   The fact             
          that petitioners routed the gifts to their own children through             
          their nieces and nephews is immaterial, and we ignore that                  
          routing for tax purposes.  We sustain respondent's determinations           
          of gift tax for 1993 relating to Larry, Kathy, John, and Sandra.            
          For the same reasons, we also agree with respondent that Kathy,             
          Sandra, and Diane are each entitled to only three exclusion                 
          amounts under section 2503 on their respective gift tax returns             
          for 1992.                                                                   
               Petitioners argue that the entire series of transactions               
          should be respected for tax purposes because Rodney gave property           
          on the same dates in 1992 and 1993, and he received nothing in              
          return.  Petitioners argue that application of the step-                    
          transaction doctrine mandates this result.  That doctrine                   
          requires that interrelated yet formally distinct steps in an                
          integrated transaction may not be considered independently of the           
          overall transaction.  See Commissioner v. Clark, 489 U.S. 726,              
          738 (1989).  When the step-transaction doctrine is applied,                 
          separate steps of a transaction are collapsed into one taxable              
          event if the steps of the series are really prearranged parts of            
          a single transaction.  See id.; Penrod v. Commissioner, 88 T.C.             




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