TOAL, Justice:
The South Carolina Tax Commission appeals the circuit court's valuation and characterization of certain transfers from the taxpayer ("Dowlings")
FACTS
In 1986 and 1987, Mr. Joab Dowling, Sr. and his wife, Katherine Dowling, ("Dowlings") transferred two thousand shares of Sherwood, Inc. to their five children. The 1986 transfers were characterized as part gift and part satisfaction...
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