Strangi Question Remains

The U.S. Court of Appeals for the Fifth Circuit in July affirmed the Tax Court's findings in Strangi II that the bona fide sale exception to Internal Revenue Code Section 2036(a) didn't apply to transfers of assets to a family limited partnership (FLP) and its corporate general partner, and that there was an implied agreement the decedent would continue to enjoy the income from assets transferred to the partnership and the corporation.¹ But while the Fifth Circuit's