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012109P.pdf   03/07/2002  Estate of Schuler  v.  CIR
   U.S. Court of Appeals Case No:  01-2109
   Agency   
Tax. The tax court's determination that the transfer of stock in family-owned business to family members constituted a reciprocal cross-gifts and the subsequent IRS's assessment of deficiencies are affirmed. Tax court's finding the gifts of stocks were interrelated was not clearly erroneous.