Estate of Albert Strangi - Page 2

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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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