Estate of Albert Strangi - Page 18

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               Thus, it intended the word “restriction” in section                    
               2703(a)(2) to be read as broadly as possible.  See                     
               Treas. Reg. sec. 25.2703-1 (a lease from a father to                   
               son will to be disregarded for transfer tax valuation                  
               purposes because it is not similar to arm’s-length                     
               transactions among unrelated parties.  [Fn. ref.                       
          Respondent next argues that the term “property” in section                  
          2703(a)(2) means the underlying assets in the partnership and               
          that the partnership form is the restriction that must be                   
          disregarded.  Unfortunately for respondent’s position, neither              
          the language of the statute nor the language of the regulation              
          supports respondent’s interpretation.  Absent application of some           
          other provision, the property included in decedent’s estate is              
          the limited partnership interest and decedent’s interest in                 
               In Kerr v. Commissioner, 113 T.C. 449 (1999), the Court                
          dealt with a similar issue with respect to interpretation of                
          section 2704(b).  Sections 2703 and 2704 were enacted as part of            
          chapter 14, I.R.C., in 1990.  See Omnibus Budget Reconciliation             
          Act of 1990, Pub. L. 101-508, 104 Stat. 1388.  However, as we               
          indicated in Kerr v. Commissioner, supra at 470-471, and as                 
          respondent acknowledges in the portion of his brief quoted above,           
          the new statute was intended to be a targeted substitute for the            
          complexity, breadth, and vagueness of prior section 2036(c); and            
          Congress “wanted to value property interests more accurately when           

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