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objectives are further evidenced by his practical incompetency
and failing health at formation and funding of SFLP and Stranco
and the short time between the partnership transactions and Mr.
Strangi’s death.
The estate asserts that property with a stated value of
$9,876,929, in the form of cash and securities, when funneled
through the partnership, took on a reduced value of $6,560,730.
It is inconceivable that Mr. Strangi would have accepted, if
dealing at arm’s length, a partnership interest purportedly worth
only two-thirds of the value of the assets he transferred. This
is especially the case given Mr. Strangi’s age and health,
because it would have been impossible for him ever to recoup this
immediate loss.
It is also inconceivable that Mr. Strangi (or his
representatives) would transfer the bulk of his liquid assets to
a partnership, in exchange for a limited interest (plus a
minority interest in the corporate general partner) that would
terminate his control over the assets and their income streams,
if the other partners had not been family members. See Estate of
Trenchard v. Commissioner, T.C. Memo. 1995-121; there the Court
found “incredible” the assertion of the executrix that the
decedent’s transfer of property to a family corporation in
exchange for stock was in the ordinary course of business. It is
clear that the sole purpose of SFLP was to depress the value of
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