Estate of Albert Strangi, Deceased, Rosalie Gulig, Independent Executrix - Page 23

                                       - 23 -                                         
          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.                   






Page:  Previous  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  Next

Last modified: May 25, 2011