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determined that the partnership was conducted in a testamentary
manner, rather than in a businesslike manner, because the
decedent’s money was used to finance the needs of individual
family members including himself. On these findings, we held
that the bona fide sale exception was not applicable.
In Estate of Strangi v. Commissioner, T.C. Memo. 2003-145,
the decedent executed a power of attorney in 1988 that named his
son-in-law, Mr. Gulig, his attorney-in-fact. In 1993, the
decedent’s health began to deteriorate, and Mr. Gulig took over
the decedent’s personal affairs. On August 12, 1994, Mr. Gulig,
as the decedent’s attorney-in-fact, independently created the
Strangi Family Limited Partnership (SFLP) and Stranco, Inc.
(Stranco), the corporate general partner of SFLP. Mr. Gulig
singlehandedly determined how the SFLP would be structured and
operated. Mr. Gulig assigned 98 percent of the decedent’s wealth
to the SFLP in exchange for a 99-percent limited partnership
interest. The assets contributed by the decedent included, among
other things, his personal residence, securities, and insurance
policies. The decedent and Mrs. Gulig (the decedent’s daughter
and Mr. Gulig’s wife), purchased Stranco shares for cash. The
decedent purchased a 47-percent interest in Stranco. Stranco
contributed the cash to SFLP for a 1-percent general partnership
interest. The Stranco shareholders acting in concert delegated
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