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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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