Strangi v. Commissioner of the I.R.S. ---> This tax case concerns the interpretation of I.R.C. 2036(a), which defines the value of the deceased's estate . Apparently Strangi was on his death bed. To hide his estate from Uncle Sam, he gave $10 million to a family limited partnership. The Tax Court found that he retained an interest in the money and made him cough up $2.5 million. Although tax law is a bit hazy in my mind, this case seems to concern the validity of using limited partnerships as tax shelters. Becaue the Fifth Circuit affirms, I gather the shelter didn't work too well. In the process of explaining why, the court clarifies the "objective bona fide sale" exception to Section 2036(a).
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