As the court found in favor of petitioner, the appellant, to the extent it determined that the decedent's October 2006 sale of his 50% interest in respondent Aurora Gems to respondent Bronstein was not an inter vivos gift, that ruling is not at issue on appeal. In any event, we note that the court's determination that the sale could not be a gift was based on the fact that, in exchange for the transfer of his interest, decedent received consideration of $10,000, paid by Bronstein...
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