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