Estate of Lillie Rosen, Deceased, Ilene Field and Herbert Silver, Co-Personal Representatives - Page 66

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          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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