Albert Strangi, Deceased, Rosalie Gulig, Independent v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• concluding transfer of assets had no legitimate non-tax rationale where the partnership “never made any investments or conducted any active business following its formation”
• concluding transfer of assets had no legitimate non-tax ratio- nale where the partnership “never made any investments or conducted any active business following its formation”
• upholding tax court's finding of an implied agreement to retain possession and control where decedent transferred 98% of his wealth to a family limited partnership (FLP
• upholding tax court’s finding of an implied agreement to retain possession and control where decedent transferred 98% of his wealth to a family limited partnership (FLP
• transfer of assets had no legitimate nontax rationale where the partnership \never made any investments or conducted any active business following its formation\
• “Because a partnership interest is worth less for tax purposes than a proportional share of the partnership’s assets — due to lack of direct control and non- liquidity — this ‘exchange’ would reduce the taxable value of the estate.”

Source: CourtListener parenthetical corpus (CC0).