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(3d Cir. 1996) (“consideration should be measured against the
value that would have been drawn into the gross estate absent the
transfer”), revg. 105 T.C. 252 (1995); United States v. Past,
347 F.2d 7, 12 (9th Cir. 1965) (“The value of what the decedent
received under the trust must be measured against the value of
the property she transferred to the trust”); United States v.
Allen, 293 F.2d 916, 917-918 (10th Cir. 1961) (consideration is
“adequate and full” only if it equals or exceeds the value of the
property that would otherwise be included in the gross estate
absent the transfer); Estate of Frothingham v. Commissioner,
60 T.C. 211, 215-216 (1973) (“unless replaced by property of
equal value that could be exposed to inclusion in the decedent’s
gross estate, the property transferred in a testamentary
transaction of the type described in the statute must be included
in his gross estate”); see also Commissioner v. Wemyss, 324 U.S.
303, 307 (1945); Estate of Gregory v. Commissioner, 39 T.C. 1012
(1963). The adequacy of consideration for purposes of the
adequate and full consideration exception is measured by the
value of the property that would have otherwise been included in
the transferor’s gross estate had the transferor died immediately
before the transfer. Estate of D’Ambrosio v. Commissioner, supra
at 313. Because transfers of assets under facts similar to those
here are typically motivated primarily (if not entirely) by
testamentary concerns, section 2036(a) preserves the integrity of
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