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    <description>A transfer of lottery winnings to the assessee&#039;s sons was treated as outside gift-tax because the underlying agreement was found to be a sham. Once that foundation was rejected, the payments under it could not be split and treated as genuine for another purpose; transactions based on a sham document must be ignored in their entirety. On that basis, the finding that no gift was involved was one of fact on the record, and no referable question of law arose from the Tribunal&#039;s order.</description>
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