CA5

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).