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In determining whether a gift of a partnership interest has been conveyed in a bona fide transaction, all of the following may be considered except:

In determining whether a gift of a partnership interest has been conveyed in a bona fide transaction, all of the following may be considered except:
the age of the donee
the degree of control retained by the donor
the donee’s right to participate in management
the manner in which the donor acquired the interest

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