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accomplishment. H. Rept. 708, 72d Cong., 1st Sess. (1932), 1939-
1 C.B. (Part 2) 457, 476; S. Rept. 665, 72d Cong., 1st Sess.
(1932), 1939-1 C.B. (Part 2) 496, 524; sec. 25.2511-1(c)(1), Gift
Tax Regs; see also Dickman v. Commissioner, 465 U.S. 330, 334 n.4
(1984) (describing the scope of the gift tax to be analogous in
breadth to the definition of gross income contained in section
61); Commissioner v. Wemyss, 324 U.S. 303, 306 (1945) (“Congress
intended to use the term ‘gifts’ in its broadest and most
comprehensive sense * * * [in order] to hit all the protean
arrangements which the wit of man can devise”).
Nevertheless, gift tax is not applicable to certain types of
transfers. “It is applicable only to a transfer of a beneficial
interest in property. It is not applicable to a transfer of bare
legal title to a trustee.” Sec. 25.2511-1(g)(1), Gift Tax Regs.
We conclude below, based on all the facts and circumstances, that
Mr. Cordes had complete control over all the Cordes corporations
and that the disputed transfers herein were only of bare legal
title and are therefore not subject to the gift tax.
A. Transfers of CFC Stock By and Between Eddy Ben Cordes
and Mrs. Cordes
Respondent contends the purported transfers of shares of
stock in CFC by and between Eddy Ben Cordes and Mrs. Cordes are
completed gifts of stock and subject to the gift tax. Eddy Ben
Cordes and Mrs. Cordes contend that because neither of them knew
of the transfers or voluntarily made those transfers, the
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