Estate of Albert Strangi - Page 43




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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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