-42-
initial contributions until October 24 and 30, 1996.20 The
reported contributions of assets by decedent’s children also were
de minimis in relation to the assets contributed by decedent; in
fact, given the cash gifts that decedent made to each of her
children surrounding their contributions to the capital of the
LRFLP, decedent arguably funded the LRFLP all by herself, see
Estate of Reichardt v. Commissioner, 114 T.C. at 155 (finding the
lack of a bona fide sale for adequate and full consideration
where, among other things, the decedent’s children transferred
nothing to the decedent or to the partnership). We also note
that decedent’s daughter, acting as decedent’s attorney-in-fact,
gave both herself and her brother a 16.4672-percent limited
partnership interest in the LRFLP before they had even made their
initial contributions.
Fourth, decedent, acting through her daughter (her
attorney-in-fact and co-trustee of the Lillie Investment Trust)
transferred substantially all of decedent’s assets, including all
of her investment assets, to the LRFLP. The management of the
transferred assets was the same both before and after the
transfer, and no meaningful change occurred in decedent’s
20 Petitioners assert that decedent’s funds were not
transferred upon the signing of the LRFLP agreement because it
took time to open the Merrill Lynch LRFLP account and to transfer
the funds into that account from the Merrill Lynch trust account.
We are unpersuaded. Decedent’s children waited more than 6 weeks
after the signing of the LRFLP agreement even to ask Merrill
Lynch to open the new account and to make the transfer.
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