MANION, Circuit Judge.
Emmett J. Doerr appeals from the district court's order holding that his payment of a disproportionate share of a joint and several obligation constituted a taxable gift to his co-obligors to the extent that his payment exceeded his proportionate share. For the reasons set forth below, we affirm.
I
In 1976, Emmett J. Doerr made substantial gifts to six donees. These gifts were subject to both federal and Wisconsin gift taxes...
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