- 57 - determination is appropriate if it is within a range of figures that may properly be deduced from the evidence. See Hamm v. Commissioner, 325 F.2d at 939-940 (holding that this Court’s valuation decision, phrased in “not less than” language, possessed sufficient definiteness and constituted an acceptable finding as to value). Overall, we have found respondent’s analysis to be more indicative of the values of the interests transferred. Factoring in the other considerations discussed earlier, we hold that the value of the remainder interest transferred by Cyril was between $90,000 and $110,000. C. Conclusion The Court of Appeals for the Ninth Circuit emphasized that, on remand, a determination of “adequate and full consideration” requires a finding that the exchanged interests are of “‘approximately equal value’”. Estate of Magnin v. Commissioner, 184 F.3d at 1081 (quoting Estate of Davis v. Commissioner, 440 F.2d 896, 900 (3d Cir. 1968), revg. 51 T.C. 269 (1971)). This Court has not interpreted the “adequate and full consideration” requirement as necessitating a dollar-for-dollar matching of consideration paid with the value of the transferred property. Estate of Carli v. Commissioner, 84 T.C. 649, 661 (1985); Estate of O’Nan v. Commissioner, 47 T.C. 648, 663 (1967). Cyril transferred a remainder interest in exchange for a life estate. The value of the remainder interest Cyril transferred was between $90,000 and $110,000. The value of the life estate Cyril received was $43,878. In the instant case, the approximately 2-Page: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Next
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