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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-
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