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e we should engage in a case-by-case analysis, the touchstone of which is "the 'transferor's intention.' " Id. at 285-86, 80 S.Ct. at 1197 (quoting Bogardus v. Commissioner, 302 U.S. 34, 43, 58 S.Ct. 61, 65, 82 L.Ed. 32 (1937)). After reading Duberstein, a reasonable taxpayer would conclude that payments
n whether Harris had a duty to pay taxes on the monies she received from Kritzik. Whether Harris had such a duty is, under Duberstein, a question of Kritzik's intent, a question whose answer can be found only upon analysis of her particular circumstances. If Kritzik harbored a donative intent, then Harr
s. That other taxpayers were found to have a donative intent does not bear on whether Harris had a duty to pay taxes on the monies she received from Kritzik. Whether Harris had such a duty is, under Duberstein, a question of Kritzik's intent, a question whose answer can be found only upon analysis of he
2 mentions1 same-page
Page ?Same page
me we should engage in a case-by-case analysis, the touchstone of which is "the 'transferor's intention.' " Id. at 285-86, 80 S.Ct. at 1197 (quoting Bogardus v. Commissioner, 302 U.S. 34, 43, 58 S.Ct. 61, 65, 82 L.Ed. 32 (1937)). After reading Duberstein, a reasonable taxpayer would conclude that payment
. That other taxpayers were found to have a donative intent does not bear on whether Harris had a duty to pay taxes on the monies she received from Kritzik. Whether Harris had such a duty is, under Duberstein, a question of Kritzik's intent, a question whose answer can be found only upon analysis of her
2 mentions1 same-page
Page ?Same page
me we should engage in a case-by-case analysis, the touchstone of which is "the 'transferor's intention.'" Id. at 285-86, 80 S.Ct. at 1197 (quoting Bogardus v. Commissioner, 302 U.S. 34, 43, 58 S.Ct. 61, 65, 82 L.Ed. 32 (1937)). After reading Duberstein, a reasonable taxpayer would conclude that payments
. That other taxpayers were found to have a donative intent does not bear on whether Harris had a duty to pay taxes on the monies she received from Kritzik. Whether Harris had such a duty is, under Duberstein, a question of EFTA00739542 Kritzik's intent, a question whose answer can be found only upon
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2 mentions1 same-page
Page ?Same page
me we should engage in a case-by-case analysis, the touchstone of which is "the 'transferor's intention.' " Id. at 285-86, 80 S.Ct. at 1197 (quoting Bogardus v. Commissioner, 302 U.S. 34, 43, 58 S.Ct. 61, 65, 82 L.Ed. 32 (1937)). After reading Duberstein, a reasonable taxpayer would conclude that payment
. That other taxpayers were found to have a donative intent does not bear on whether Harris had a duty to pay taxes on the monies she received from Kritzik. Whether Harris had such a duty is, under Duberstein, a question of Kritzik's intent, a question whose answer can be found only upon analysis of her
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Entities connected to both Bogardus and Kritzik
