Estate of Hilde E. Erickson, Deceased, Donor, Karen E. Lange, Personal Representative - Page 25




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          the Partnership, however, would have a significant asset base               
          from which to recover from the Partnership, over $2 million.                
          Finally, the estate argues that the Partnership facilitated Mrs.            
          Erickson’s gift-giving plan.  Facilitating a gift-giving plan is            
          not a significant nontax purpose.  See Estate of Rosen v.                   
          Commissioner, supra.  We find none of the estate’s asserted                 
          nontax purposes for forming the Partnership compelling.                     
               Moreover, the facts and circumstances surrounding the                  
          transaction also fail to show any nontax purpose for the                    
          Partnership.  The Partnership was mainly a collection of passive            
          assets, primarily marketable securities and rental properties               
          that remained in the same state as when they were contributed.              
          In addition, the same investment advisers and property managers             
          managed the assets both before and after the transfers to the               
          Partnership.  The estate highlights the slight shift in the                 
          Partnership’s investment allocation from bonds to real estate as            
          proof that the partners made deliberate, businesslike investment            
          decisions.  We cannot discern, however, any business goals or any           
          particular reasons for the Partnership to invest in certain                 
          assets.  We note also that the Partnership made loans to family             
          members and, indeed, in at least one instance, even lowered an              
          interest rate that a partner had previously agreed to pay.  We              
          find that the Partnership was a mere collection of mostly passive           








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