Estate of Albert Strangi - Page 28

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               I believe that, rather than holding that the economic                  
          substance doctrine is satisfied in the instant case, the Court              
          should conclude that the economic substance doctrine does not               
          apply to disregard a validly formed entity where the issue is the           
          value for Federal gift and estate tax purposes of the interest              
          transferred in that entity.  In that regard, I agree with Judge             
          Foley's concurring opinion in Knight v. Commissioner, 115 T.C.              
          ___, ___ (2000).                                                            
               FOLEY, J., agrees with this concurring opinion.                        

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