Estate of Albert Strangi - Page 42




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          Heintz v. Commissioner, 25 T.C. 132 (1955); Ericsson Screw                  
          Machine Prods. Co., v. Commissioner, 14 T.C. 757 (1950); King               
          Enters., Inc. v. United States, 189 Ct. Cl. 466, 475, 418 F.2d              
          511, 516 (1969)).  The end-result test is flexible and grounds              
          tax consequences on what actually happened, not on formalisms               
          chosen by the participants.  See Penrod v. Commissioner, supra.             
               The sole purpose of the transactions orchestrated by Mr. and           
          Mrs. Gulig was to reduce Federal transfer taxes by depressing the           
          value of Mr. Strangi’s assets as they  passed through his gross             
          estate, to his children, via the partnership.  The arrangement              
          merely operated to convey the assets to the same individuals who            
          would have received the assets in any event under Mr. Strangi’s             
          will.  Nothing of substance was intended to change as a result of           
          the transactions and, indeed, the transactions did nothing to               
          affect Mr. Strangi’s or his children’s interests in the                     
          underlying assets except to evidence an effort to reduce Federal            
          transfer taxes.  The control exercised by Mr. Strangi and his               
          children over the assets did not change at all as a result of the           
          transactions.  For instance, shortly after Mr. Strangi’s death              
          SFLP made substantial distributions to the children, the Merrill            
          Lynch account was divided into 4 separate accounts to allow each            
          child to control his or her proportionate share of SFLP assets,             
          and distributions were made to the estate to enable it to pay               
          death taxes and post a bond.  Mr. Strangi’s testamentary                    






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