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C. Conclusion
The record demonstrates that the structure that decedent
employed through her legal representatives and family was merely
a testamentary vehicle employed to shift her assets to future
generations while maintaining her continued right to benefit from
the FLP interests transferred. This is precisely the type of
situation for which section 2036 was created. Accordingly, we
sustain respondent’s determination, subject to the parties’
concessions.
Decision will be entered
under Rule 155.
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