Charles T. McCord, Jr. and Mary S. McCord, Donors - Page 103

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          petitioners should be regarded as having made a charitable gift             
          to CFT of a partial interest in their MIL limited partnership               
          interest, which charitable gift would be subject to the gift tax            
          disallowance provision of section 2522(c)(2).3                              































               3  I recognize that under the disallowance rule of sec.                
          2522(c)(2), as suggested herein, petitioners’ claimed charitable            
          deduction for their gift to Symphony also would be disallowed as            
          a gift of a partial interest.                                               

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