hich governs Freeze Entities) would be meaningless if Section 2036 applies to include the Freeze Entity assets in Unit holders' taxable estates. The Strangi court focused on powers over partnership distributions and applied Section 2036(a)(2) to conclude that the partnership assets should be included in

alue higher than liquidation value. Inclusion of Freeze Entity Assets in the Investor's Estate under Section 2036 Courts following the decisions in Strangi v. Commissioner have held that investment assets contributed to a family limited partnership ("FLP") in exchange for partnership interests should b

ngi (and Kill the Monster Again), Part 1 by Richard L. Dees :: SSRN In part one of a two-part article, the author places the recent cases, such as Strangi, including some family limited partnership (FLP) interests in a partner's Like • Comment RIBroc Brock Pierce shared an article k Pierce le:,1i