Blake v. Commissioner, 42 T.C.M. (CCH) 1336, 1351 (1981), aff'd, 697 F.2d 473 (2d Cir. 1982). In a 1994 case, the appellate court summarized Blake: "In Blake v. Commissioner, a taxpayer-donated appreciated stock to a charity with an understanding that the charity would liquidate the stock and purchase the taxpayer's yacht. See 697 F.2d at 478-79. We applied the step transaction doctrine to disregard the initial gift of the stock, and treated the transaction as a gift of the yacht. Id. at 480." (Gift of stock plus charity's exemption plus purchase of yacht from donor equals sale of stock and gift of yacht.)