Estate of Albert Strangi, Deceased, Rosalie Gulig, Independent Executrix - Page 2

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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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