MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
These cases were consolidated for trial, briefing, and opinion. By notices dated May 11, 1994, respondent determined a deficiency in decedent's 1990 gift tax in the amount of $23,029 and in petitioner's estate tax in the amount of $47,061. The issue before the Court is whether petitioner may disavow the form of, and previous tax reporting relating to, a transaction. We hold that petitioner may not.
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