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The Court also concluded that the Decedent’s transfers (a mere

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cheap ray bans The Court held that marketable securities transferred by a decedent to Family Limited Partnership cheap ray bans, which the Estate discounted for lack of control and marketability were includible in Decedent’s estate because an implied agreement existed between the Decedent and his family that the Decedent would retain enjoyment and economic benefit of the transferred property. The Court also concluded that the Decedent’s transfers (a mere recycling of value) to the Family Limited Partnership did not constitute “bona fide sales” within the meaning of Section 2036(a) because the Decedent did not replenish his Estate with other assets of equal value and said that although a bona fide sale does not necessarily require an arms length transaction between the transferor and an unrelated third party, it still must be made in good faith. A good faith transfer to a Family Limited Partnership must provide the transferor some potential for benefit other than the potential estate tax advantages than might result from holding assets in the Partnership form. cheap ray bans

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