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COHEN, Judge: On December 1, 1998, respondent determined a
$2,545,826 deficiency in the Federal estate tax of the estate of
Albert Strangi, Rosalie Gulig, independent executrix. In the
alternative, respondent determined a Federal gift tax deficiency
of $1,629,947.
After concessions by the parties, the issues for decision
are (alternatively): (1) Whether the Strangi Family Limited
Partnership (SFLP) should be disregarded for Federal tax purposes
because it lacks business purpose and economic substance;
(2) whether the SFLP is a restriction on the sale or use of
property that should be disregarded pursuant to section
2703(a)(2); (3) whether the transfer of assets to SFLP was a
taxable gift; and (4) if SFLP is not disregarded, the fair market
value of decedent’s interest in SFLP at the date of death.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect as of the date of decedent’s
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference. Albert
Strangi (decedent) was domiciled in Waco, Texas, at the time of
his death, and his estate was administered there. Rosalie
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