- 100 -
presented in each of the instant cases:
(1) Was there a transfer of property by the dece-
dent?
(2) If there was a transfer of property by the
decedent, was such a transfer other than a bona fide
sale for an adequate and full consideration in money or
money’s worth?
(3) If there was a transfer of property by the
decedent that was other than a bona fide sale for an
adequate and full consideration in money or money’s
worth, did the decedent retain possession or enjoyment
of, or the right to income from, the property trans-
ferred?
Transfer of Property by the Decedent
Mr. Stone’s estate concedes that Mr. Stone made a transfer
of property to each of the Five Partnerships in exchange for the
general and limited partnership interests in each such partner-
ship that he owned on the date of his death. Ms. Stone’s estate
concedes that Ms. Stone made a transfer of property to each of
the Five Partnerships in exchange for the limited partnership
67(...continued)
has retained for his life or for any period not ascer-
tainable without reference to his death or for any
period which does not in fact end before his death--
(1) the possession or enjoyment of, or the
right to the income from, the property * * *
Page: Previous 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 NextLast modified: May 25, 2011