Michael T. Caracci and Cindy W. Caracci, et al. - Page 67

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               On the evidence before us, we conclude that the transfers of           
          the home health care assets to the for-profit entities                      
          constituted gifts to the Caracci children, and not the                      
          realization of taxable income by them.  They are not subject to             
          income taxes on those transfers.                                            
               In view of the foregoing,                                              

                                             Decisions will be entered for            
                                        petitioners in docket Nos.                    
                                        14711-99X, 17336-99X, and                     
                                        17339-99X, and will be entered                
                                        under Rule 155 in the remaining               
                                        dockets.                                      

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