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SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: This matter is before the Court on remand
from the Court of Appeals for the Fifth Circuit for further
consideration consistent with its opinion in Estate of Strangi v.
Commissioner, 293 F.3d 279 (5th Cir. 2002) (Strangi II), affg. in
part and revg. and remanding in part 115 T.C. 478 (2000)
(Strangi I). The issue for decision on remand is whether the
value of property transferred by Albert Strangi (decedent) to the
Strangi Family Limited Partnership (SFLP) and Stranco, Inc.
(Stranco), is includable in his gross estate pursuant to section
2036(a). Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect as of the date of death,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
FINDINGS OF FACT
Facts with respect to this case were found in our original
opinion in Strangi I and are incorporated by this reference. We
summarize for convenience relevant facts from Strangi I and set
forth additional findings for purposes of deciding the issue on
remand.
General Background
Decedent and his first wife had four children: Jeanne,
Rosalie, Albert T., and John Strangi (collectively the Strangi
children). After divorcing his first wife in 1965, decedent
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