-43-
relationship to her assets after the transfer. See Estate of
Schutt v. Commissioner, T.C. Memo. 2005-126; Estate of Korby v.
Commissioner, T.C. Memo. 2005-103; Estate of Korby v.
Commissioner, T.C. Memo. 2005-102; Estate of Schauerhamer v.
Commissioner, T.C. Memo. 1997-242. We also note that during the
first 4 years of the LRFLP’s existence, i.e., the last 4 years of
decedent’s life, decedent’s daughter (as decedent’s attorney-in-
fact) gave away almost 65 percent of decedent’s limited
partnership interest.
Fifth, after the transfer of the assets to the LRFLP,
decedent was unable to meet her financial obligations without
using funds of the LRFLP. In fact, all of the funds that were
withdrawn from the LRFLP were used for decedent’s benefit.
Before decedent died, that benefit included the payment of her
personal living expenses and the carrying out of her intent to
make significant annual gifts to each of her descendants. After
decedent died, that benefit included the satisfaction of the
bequests set forth in the Lillie Investment Trust, the payment of
costs related to administering her estate, and the satisfaction
of her Federal estate tax liability. The use of the LRFLP’s
funds to satisfy those obligations of decedent is inconsistent
with a finding of a bona fide sale. See Estate of Thompson v.
Commissioner, 382 F.3d 367 (3d Cir. 2004); Estate of Korby v.
Commissioner, T.C. Memo. 2005-103; Estate of Korby v.
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