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Although we can certainly understand why respondent makes
this argument, we shall reject it. Decedent’s execution of the
assignment combined with her exercise of dominion and control
over the Marital Fund assets after January 8, 1997, and her use
of Marital Fund assets after she executed the assignment
convinces us that decedent intended to withdraw the Marital Fund
assets on January 8, 1997, and that she actually did so before
she died on June 12, 1997.
D. Decedent’s Alleged Transfers of Marital Fund Assets
Petitioner argues that decedent’s execution of the
assignment on January 8, 1997, also effected transfers of Marital
Fund Assets to GFLP. Respondent argues that the assignment did
not result in a completed transfer to GFLP that satisfies the
requirements for valid inter vivos gifts under Oklahoma law.
All of the alleged transfers described in the assignment,
except perhaps one, are transfers for no consideration; i.e,
gifts. The only alleged transfer that may not be a gift is the
alleged transfer of Marital Fund assets to GFLP. With respect to
this alleged transfer, petitioner argues that the transfer was a
bona fide sale for an adequate and full consideration in money or
money’s worth within the meaning of section 2036(a), and
respondent argues that it was not. For purposes of this part of
our analysis, we focus only on whether decedent’s execution of
the assignment resulted in a completed transfer of property to
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