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and Loretta as well as to Albert and Gregory. Shares were
transferred to Gayle even though she told the Bieses that she did
not want to be in the funeral home business.
Beginning in 1985, and each year until her death, decedent
transferred shares of MBI stock to Albert, Gayle, Gregory, and
Loretta. Beginning in 1991, and each year until her death,
decedent transferred shares of MBI stock to James and his wife
Cheryl. Each transfer was to an individual, and each transfer
was the number of shares or fraction of a share calculated by Mr.
Grayson to be equal in value to $10,000.
The procedure was the same for each of the 27 transfers at
issue: Mr. Grayson would prepare the certificates to transfer
MBI shares to Albert, Gayle, Gregory, and Loretta, and at the
same time, he would prepare the certificates for the shares
transferred from Gayle to Albert, and from Loretta to Gregory.
After Mr. Grayson had prepared all transfer documents, he would
deliver them to the funeral home for endorsement. Albert, as
president of MBI, endorsed all the certificates before delivery
to the donees, including the shares that would be issued to
Albert and Gregory once Gayle and Loretta endorsed the
certificates for transfer. Gayle and Loretta transferred the
shares received from decedent to their husbands upon receipt.2
2The stock transfers from Gayle and Loretta to Albert and
Gregory, respectively, were dated the day after decedent's
(continued...)
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