Estate of Cyril I. Magnin, Deceased, Donald Isaac Magnin, Executor - Page 58

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          to-1 disparity between the remainder interest transferred by                
          Cyril and the consideration received by Cyril does not support a            
          finding that the two interests were of “approximately equal                 
          value”.  Therefore, we hold that Cyril did not receive “adequate            
          and full consideration” for the remainder interest he transferred           
          to his children.  The estate is entitled to an offset of $43,878            
          under section 2043 for the partial consideration received by                
          Cyril.                                                                      
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          

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