115 T.C. No. 35
UNITED STATES TAX COURT
ESTATE OF ALBERT STRANGI, DECEASED, ROSALIE GULIG, INDEPENDENT
EXECUTRIX, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4102-99. Filed November 30, 2000.
D formed a family limited partnership (SFLP) and
transferred assets, including securities, real estate,
insurance policies, annuities, and partnership
interests, to SFLP in return for a 99-percent limited
partnership interest. Held: (1) The partnership was
valid under State law and will be recognized for estate
tax purposes. (2) Sec. 2703(a), I.R.C., does not apply
to the partnership agreement. (3) The transfer of
assets to SFLP was not a taxable gift. (4) R’s
expert’s opinion as to valuation discounts is accepted.
Norman A. Lofgren and G. Tomas Rhodus, for petitioner.
Deborah H. Delgado, Gerald L. Brantley, Sheila R. Pattison,
and William C. Sabin, Jr., for respondent.
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