Strangi II Where From Here?

The Tax Court's second opinion in the now famous Estate of Strangi v. Commissioner (Strangi II)¹ sent shockwaves throughout the estate-planning profession and created new stumbling blocks for practitioners who create family limited investment partnerships or family limited liability companies (FLPs). While the decision addresses the application of both Internal Revenue Code Sections 2036(a)(1) and 2036(a)(2) to an FLP to cause the assets transferred to an FLP to be