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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.