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“refinements of title”, but with the realities of ownership.
Corliss v. Bowers, 281 U.S. 376, 378 (1930); see also Heyen v.
United States, 945 F.2d 359, 363 (10th Cir. 1991) (“[S]ubstance
over form analysis applies to gift tax, as well as to income tax,
cases.”); Chanin v. United States, 183 Ct. Cl. 840, 393 F.2d 972,
978–980 (1968); Estate of Murphy v. Commissioner, T.C. Memo.
1990–472.
As judgment creditors, the Danzig claimants could have
brought suits in all 10 States to have these transfers set aside.
Instead, as an alternative remedy, they sought and obtained a
money judgment against Mrs. Grynberg, the transferee. In so
doing, the Danzig claimants suffered no harm from the convey-
ances; once more, they could look to the assigned properties as a
source of payment. Hence, by relegating his creditors to
Mrs. Grynberg for satisfaction of their claims against him,
petitioner continued to enjoy the mineral interests. And, as we
have noted above, Congress does not treat as taxable gifts trans-
fers of property where the donor has not fully parted with his
interest therein. See Estate of Sanford v. Commissioner, 308
U.S. at 43; sec. 25.2511–2(b), Gift Tax Regs.
This Court made a similar ruling in Paolozzi v. Commis-
sioner, 23 T.C. 182 (1954). There, the taxpayer transferred
property in trust, the income of which was distributable to her
in the discretion of the trustees. Motivated by fear that the
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