Estate of Strangi v. Commissioner
United States Tax Court
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 partnership agreement. (3) The transfer of assets to SFLP was not a taxable gift.
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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 partnership agreement. (3) The transfer of assets to SFLP was not a taxable gift. (4) R's expert's opinion as to valuation discounts is accepted.
1Opinion of the Court
ESTATE OF ALBERT STRANGI, DECEASED, ROSALIE GULIG, INDEPENDENT EXECUTRIX, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Strangi v. Commissioner
No. 4102-99
United States Tax Court
115 T.C. 478; 2000 U.S. Tax Ct. LEXIS 89; 115 T.C. No. 35;
November 30, 2000, Filed
PARR, J., agrees with this dissenting opinion.
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…
Also in this document: Concurrence · Laro; Concurrence · Wells; Dissent · Parr; Dissent · Ruwe; Dissent · Beghe.
2Cases cited52 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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