Robert Rosano, as of the Estate of Mary R. Rosano v. United States

VAN GRAAFEILAND, Senior Circuit Judge:

The parties do not dispute the facts, which are aptly summarized in the Report and Recommendation of Magistrate Judge Orenstein, which was adopted, with minor modifications, by Judge Seybert. Rosano v. United States, 67 F.Supp.2d 113 (E.D.N.Y.1999). This case concerns an attempt by the decedent, Mary Rosano, to decrease the amount of money in her taxable estate by making gifts of less than $10,000 to numerous relatives and friends. She did this by writing checks to relatives and friends. Mary Rosano died on January 21, 1990. The checks in question were…