The document discusses the court's analysis of whether the decedent's inter vivos transfer of property to a partnership should be included in the decedent's gross estate under Section 2036(a). The court focused on whether the decedent retained an interest in the transferred property and whether the transfer was a bona fide sale. The court concluded that the decedent retained an interest in the property and that the transfer was not a bona fide sale.
documents/vol00010-efta01459940-pdf.pdf
{"key_people":["Decedent","Mr. Holliday","Mrs. Holliday"],"document_type":"legal","document_subtype":"court analysis","key_organizations":["Partnership","Estate","Service","Court"],"reference_numbers":["DB-SDNY-0120735","SDNY_GM_00266919","EFTA01459940"]}