Under several Internal Revenue Code sections, the property a person transfers will remain in his gross estate if he retains certain rights or powers over it. There is is an exception for transfers made for a “bona fide sale for an adequate and full consideration in money or money's worth,” in IRC Sections 2035, 2036, 2037 and 2038, among others. But what, exactly, is a bona fide sale? Recent rulings have shed some light. Unfortunately, the federal appeals courts do not agree. It
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