Legal Opinion
Estate of Albert Strangi v. Commissioner
United States Tax Court
Decided November 30, 2000No. 4102-99Unknown
1Opinion of the Court
115 T.C. No. 35
UNITED STATES TAX COURT ESTATE OF ALBERT STRANGI, DECEASED, ROSALIE GULIG, INDEPENDENT EXECUTRIX, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4102-99. Filed November 30, 2000. D formed a family limited partnership (SFLP) and transferred assets, including securities, real estate, insurance policies, annuities, and partnership interests, to SFLP in return for a 99-percent limited partnership interest. Held: (1) The partnership was valid under State law and will be recognized for estate tax purposes. (2) Sec. 2703(a), I.R.C., does not apply to the…
2Cases cited50 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. CliffordSupreme Court of the United States · 1940
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- United States v. CartwrightSupreme Court of the United States · 1973
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
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