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agreement contemplated that more than one partner would
contribute property to RLP but that decedent and her sons never
intended that anyone other than her (or her, through her
revocable trust) would actually contribute property to RLP.
As to the need for a significant nontax business purpose, we
inquire whether the transfer of assets to RLP was reasonably
likely to serve such a purpose at its inception. See Strangi v.
Commissioner, 417 F.3d 468, 480 (5th Cir. 2005), affg. T.C. Memo.
2003-145. The estate asserts that the motivation behind the
formation of RLP was the desire to benefit from estate tax
savings, the ability to give away partnership interests, the need
to protect decedent’s assets from her creditors, and the desire
to diversify decedent’s assets. We disagree with the estate that
decedent had the requisite purpose when she transferred her
assets to RLP. The estate’s stated goal of gift-giving is a
testamentary purpose and is not a significant nontax business
purpose. See Estate of Bigelow v. Commissioner, supra; see also
Estate of Schauerhamer v. Commissioner, T.C. Memo. 1997-242. Nor
is the estate’s stated goal of efficiently managing assets such a
purpose, given the lack of evidence that RLP required any special
kind of active management. See Estate of Bigelow v.
Commissioner, supra. The protection of assets against creditors
also is not such a purpose in that the record does not establish
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