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eliminated by George's transfer of stock with a total value of
$59,778 to decedent's son, Jay, in the 3 years following
decedent's death. Thus, it is clear that decedent's family
members received stock of approximately the same economic value
via the circuitous route devised by decedent, his brother, and
their insurance agent as they would have by direct transfers from
decedent.
Finally, the estate asserts that the reciprocal transaction
doctrine does not apply to this case because decedent would have
made the transfers to his brother's family even if George had
made no reciprocal transfers to decedent's family. We disagree.
We find implausible the estate's assertion that decedent
would have transferred gratuitously assets sufficient to severely
deplete his net worth. Moreover, it well settled that the
Federal estate tax does not hinge upon the subjective intent of
the decedent. See United States v. Estate of Grace, supra at
323. Relevant to the decision in this case is that the objective
facts prove conclusively that decedent and his brother executed a
plan to make simultaneous, reciprocal transfers of property of
approximately equal economic value to each other's family
members, and that decedent's immediate family members received
property of approximately the same economic value as they would
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