In reaching its conclusion to deny the deduction, the Tax Court held that the transfer of the home was not the transfer of an undividedinterest in the property.
FORBES: Patel v. Commissioner: Gift of a Partial Interest
2.
Once the fire department destroyed the home, Gale posited, the Patels retained no substantial interest in the home, and thus would have transferred an undividedinterest in the property.
FORBES: Patel v. Commissioner: Gift of a Partial Interest
3.
The ETF represents a fractional, undivided beneficial ownership interest in the SPDR Gold Trust.