-66-
thereof that relates to the limited partnership interest that
decedent transferred by gift more than 3 years before her death.
We disagree. Petitioners’ argument, as we understand it, is that
this Court in Estate of Bongard v. Commissioner, 124 T.C. at
131-132, concluded that section 2035(a), which pertains to assets
transferred by gift within 3 years of death, limits the reach of
section 2036(a)(1). Petitioners are mistaken. Decedent
continued to possess and enjoy the transferred assets up until
her death. Accordingly, section 2036(a)(1) includes those assets
in her gross estate.
6. Epilog
We hold for respondent. We have considered all arguments by
petitioners for a contrary holding and find those arguments not
discussed herein to be without merit. To reflect the parties’
concessions,
Decisions will be entered
under Rule 155.
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