The partnership cases over the last 5 years (since what has become known as Strangi II, T.C. Memo.2003-145) have provided the tax planner with a reasonable roadmap as to how to structure sustainable partnerships for estate tax planning purposes. The cases established that the Tax Court is more than willing to apply a broad reading and liberal application of Code section 2036, meaning that it will apply 2036 to partnership cases to ignore the partnership for purposes of valuing partnership assets.
Read entire article here.