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benefit from the transferred property for purposes of section
2036(a)(1).
First, we cannot lose sight of the fact that decedent
contributed approximately 98 percent of his wealth, including his
residence, to the SFLP/Stranco arrangement. Respondent alleges
that the transfer left decedent with inadequate assets and cash
flow to meet his living expenses, to which the estate takes
objection. The estate goes to great lengths to counter
respondent’s assertion, claiming that decedent at his death
possessed liquefiable assets of at least $172,000 and received on
a monthly basis a pension of $1,438.18 and Social Security of
$1,559. The estate also stresses that respondent has not
established the amount of decedent’s living expenses and
maintains that, even if the $33,323.22 in checks paid from
decedent’s account in August and September were used as an
estimate, the purported liquefiable assets would have covered
decedent’s needs for his concededly short life expectancy of 12
to 24 months. However, the relative dearth of liquefied
(decedent’s Form 706 showed two bank accounts with funds totaling
$762), as opposed to “liquefiable”, assets persuades us that
decedent and his children and Mr. Gulig all expected that SFLP
and Stranco would be a primary source of decedent’s liquidity.
It is unreasonable to expect that decedent would be forced to
rely on sale of assets to meet his basic costs of living.
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