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that a finding of a bargained-for consideration is not
necessary to establish reciprocity. [United States v.
Estate of Grace, 395 U.S. at 325 n.10.]
In this case, the transfers were interrelated. We have no
doubt that decedent's transfers of stock to his brother's family
were quid pro quo for George's transfers of stock to decedent's
family; the exchanged stock was the bargained-for consideration.
Furthermore, the brothers' plan to exchange the stock via
transfers to each other's families on the same days in 1994 and
1995 establishes that the transfers were reciprocal. See Lehman
v. Commissioner, supra at 100-101 ("Here the transfer by the
decedent's brother, having been paid for and brought about by the
decedent, was in substance a 'transfer' by the decedent".).
The estate contends that decedent was not left in the same
economic position after the transfers as his net worth was
"severely depleted". The estate misconstrues the reciprocal
transaction doctrine. The relevant inquiry in reciprocal
indirect transfer cases is whether the transferees are in
approximately the same economic position as they would be if the
donor transferred the property directly to them. See Schultz v.
United States, supra; Furst v. Commissioner, supra. Here, in
simultaneous, circuitous transfers, decedent conveyed stock with
a total value of $440,467.20 to his brother's family, and George
conveyed stock with a total value of $382,140 to decedent's
family. The difference in these amounts, $58,327.20, was
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