result, the Court concluded that there was no gift made by Edward.
However, at Sumnees trial, the Tax Court stated,
There is no evidence that any dispute existed ... concerning ownership of Sumnees stock
or that Mickey was determined to withhold any of Sumner's shares from him. To the contrary: the
evidence showed that Mickey and Sumner were ... effort to
achieve that goal. Because no demand was ever placed on Sumnees shares, no negotiations ever
occurred concerning his ownership of those shares. Sumner never filed a lawsuit
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01459106.pdf