June Cordes, et al. - Page 43

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               Mr. Cordes’s absolute control over all aspects of the Cordes           
          family dealerships--stock, financial, and operational--was such             
          that we must conclude he was the beneficial owner of all of the             
          Cordes family dealerships.                                                  
               Because Mr. Cordes owned all beneficial interest in the                
          Cordes family dealerships during the taxable years at issue, all            
          of the disputed transfers were solely of legal title.  Because              
          such transfers of legal title are not subject to the gift tax, we           
          must hold for petitioners with respect to the gift tax cases                
          involving stock in the Cordes family dealerships.                           
          III.  Conclusion                                                            
               We have carefully considered all remaining arguments made by           
          the parties for contrary holdings and, to the extent not                    
          discussed, find them to be irrelevant or without merit.                     
               To reflect the foregoing,                                              

                                                  Decisions will be entered           
                                              under Rule 155.                         

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