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okay so we have left off last time talking about the taxation of gifts and letamp;#39;s just summarize briefly the some of the main points that we we made the first thing we learned is that under section 102 a of the code the value of a gift whether in money or property is excluded from gross income now i want to emphasize again that the issue of the taxation of gifts that we study is completely separate and distinct from another issue involving the gift tax and particularly whether the transfer or the party making the gift has any tax liability under the gift tax under the gift tax certain transfer wars are going to have gift tax liability because theyamp;#39;re essentially giving some of their wealth away but that holds tax system and the law there and all of the definitions and so forth are completely separate and distinct from the issue that we focus on what weamp;#39;re focusing is not on taxing the transfer or that whether the transferee the recipient of this purported gift ha