7.28. The eligible amount of a gift of a property by a taxpayer is equal to zero if it can reasonably be concluded that the gift relates to a transaction or series of transactions(a) one of the purposes of which is to avoid the application of section 7.25 to the gift of a property; or
(b) that would, if this Part were read without reference to this paragraph, result in a tax benefit to which section 1079.10 applies.