Estate of Albert Strangi, Deceased, Rosalie Gulig, Independent Executrix - Page 47

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          amounts should be distributed.  The preponderance of the evidence           
          therefore establishes that the full value of the transferred                
          assets is includable under section 2036(a).                                 
               Pursuant to section 2036(a), 99 percent of the net asset               
          value of SFLP and 47 percent of the value of assets held by                 
          Stranco should be included in decedent’s gross estate.                      
          Nonetheless, because respondent never asserted an increased                 
          deficiency in connection with the section 2036 issue, valuation             
          of the property in dispute, i.e., interests in SFLP and Stranco,            
          will be limited by the amounts determined in the notice of                  
          deficiency.  The decision to be entered, however, will take into            
          account any additional deductions to which the estate is entitled           
          for costs and expenses incurred subsequent to the initial trial             
          of this case.                                                               
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          

















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Last modified: May 25, 2011