OPINION
BYBEE, Circuit Judge:
Anne Y. Petter ("Taxpayer" or "Anne") transferred membership units in a family-owned LLC partly as a gift and partly by sale to two trusts and coupled the transfers with simultaneous gifts of LLC units to two charitable foundations. The transfer documents include both a dollar formula clause — which assigns to the trusts a number of LLC units worth a specified dollar amount and assigns the remainder of the units to the...
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