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his wife, because both of them continuously held the properties
jointly.
In any event, he argues next, Mrs. Grynberg’s signature on
blank assignment forms proves that he reserved the power to
revoke the transfers at any time, rendering the conveyances
incomplete for gift tax purposes. And, finally, petitioner
alleges that, even if he gifted the properties, they had no
realistic values because the Danzig case cast a cloud on title.
Respondent claims that, although petitioner intended by his
actions to defraud the Danzig claimants, his act of executing and
recording the assignments in Mrs. Grynberg’s name, ipso facto,
created gifts. In asserting that the evidence is insufficient to
prove the existence of blank assignment forms, respondent
concludes that petitioner relinquished his entire interest in the
properties to his wife, and that, consequently, “[Mrs. Grynberg]
could have done what she wanted with the leases and overrides.”
Lastly, respondent maintains that the gross value of the
mineral interests should not be reduced by any debt encumbering
the properties because a “willing buyer with knowledge of
relevant facts would know that the Danzig plaintiffs would not
stand in the way of a purchase which would pay them full value”.
We reject respondent’s contentions and hold that petitioner did
not make gifts of mineral interests to his wife.
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