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at 403-404, and Ryerson v. United States, supra at 408, regarding
contingency and joint action are not restricted in their
applicability to indirect gift situations. In Skouras v.
Commissioner, 14 T.C. 523, 524-525 (1950), affd. 188 F.2d 831 (2d
Cir. 1951), the taxpayer assigned outright all incidents of
ownership in several insurance policies on his life to his five
children jointly and continued to pay the premiums thereon.
Given these facts, we, citing United States v. Pelzer, supra,
stated broadly that “where the use, possession, or enjoyment of
the donee is postponed to the happening of future uncertain
events the interest of the donee is a future interest within the
meaning of the statute.” Id. at 533. Then, relying on Ryerson
v. United States, supra, and in spite of the taxpayer’s argument
that “there was not a grant to trust as in the Ryerson case”, we
ruled that the taxpayer, by “making the assignments to his five
children jointly, had postponed the possession and enjoyment of
the rights and interests in and to the policies or the proceeds
thereof until his death or until such time as the children,
acting jointly, might change or negative the action he had thus
taken.” Id. at 534.
In sum, we reject petitioners’ contention that when a gift
takes the form of an outright transfer of an equity interest in a
business or property, “No further analysis is needed or
justified.” To do so would be to sanction exclusions for gifts
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