EFTA01126625.txt

"Estate of Schauerhamer v. Commissioner T.C. Memo 1997-242... Decedent was diagnosed with colon cancer"

"Estate of Reichardt v. Commissioner, 114 T.C. 144 (2000)... Decedent, after just being diagnosed with terminal cancer"

"Estate of Harper v. Commissioner T.C. Memo 2002-121... Decedent was an attorney"

"Mr. Strangi and the other shareholders of Stranco (Strangi children)"

"98% of decedent's property... was contributed to the partnership in exchange for a 99% limited partnership interest."

"Decedent purchased 47% of the shares of the corporate general partner for cash"

"Albert Strangi ("decedent") executed an extremely broad durable power of attorney in favor of Michael J. Gulig, his son-in-law."

"the IRS determined a deficiency in federal estate tax... Strangi's first appearance before the Tax Court was in response to the above deficiencies."

"the Lillie Investment Trust received a 99% limited partnership interest"

"the Lillie Investment Trust contributed approximately $2.4 million... Mrs. Rosen's daughter, as co-Trustee of the Lillie Investment Trust, directed th"

"Mrs. Gore executed a durable power of attorney in favor of her daughter, Pamela Powell"

"naming herself and her son John Rector, as co-Trustees"

"Sidney Gore died in January, 1995, survived by his wife, Sylvia"

"Arthur Erickson died in May, 1984, leaving his assets to his wife, Hilde Erickson"

"Mrs. Erickson and Karen Lange, one of the Ericksons' daughters"

"with her other daughter, Sigrid Knuti"

"Chad Lange (Mrs. Erickson's son-in-law)"

"Mrs. Erickson executed a durable power of attorney in 1994 in favor of Karen"

"Karen and Sigrid were general partners and limited partners"

"Karen and Sigrid were general partners and limited partners"

"Mrs. Erickson would contribute marketable securities plus a Florida condominium in exchange for an 86.25% limited partnership interest"

"The approximate fair market value of these contributed assets was $2.1 million"

"$140,000 was loaned to Sigrid to enable her to purchase a Florida condominium"

"A loan of $70,000 was also made to Chad"

"Mrs. Erickson and Karen Lange, one of the Ericksons' daughters, were the Trustees of the credit shelter trust"

"ord began the funding of HI-1 with her individual stock and cash assets"

"Mrs. Hurford authorized Chase to transfer over $1 million from Mr. Hurford's estate account to HI-1"

"Mr. Garza prepared another "form" letter for Mrs. Hurford to transfer the Hunt Oil phantom stock to HI-2"

"HI-3 was created to receive the real property owned by Mrs. Hurford, individually"

"Two of the Hurford children entered into a private annuity with Mrs. Hurford on April 5, 2000"

"Two of the Hurford children entered into a private annuity with Mrs. Hurford on April 5, 2000"

"During the lifetime of Gary and Thelma Hurford"

"the Hurford family hired a new estate planning attorney, Joe Garza"

"Maude Williams and her husband, Roger Williams"

"and Ms. Williams' grandson, Michael Anderson"

"The Petititioner, Jane Z. Astleford ("Mrs. Astleford"), and her husband, M.G. Astleford ("MG")"

"In 1970, MG and Richard Burger formed Pine Bend Development Co."

"In 1970, MG and Richard Burger formed Pine Bend Development Co."

"Pine Bend purchased agricultural property in Rosemount, Minnesota (the "Rosemount Property")"

"On August 1, 1996, Mrs. Astleford created the Astleford Family Limited Partnership ("AFLP")"

"she retained a 10% interest in AFLP, as general partner"

"Mrs. Astleford transferred her ownership interest in an elder care assisted living facility to AFLP with a value of $870,904"

"The Petititioner, Jane Z. Astleford ("Mrs. Astleford")"

"Thomas H. Holman, Jr. ("Tom") was employed by Dell Computer Corp"

"Tom .89% general partner and 49.04% limited partner"

"Kim .89% general partner and 49.04% limited partner"

"Tom's mother was the Trustee"

"Tom transferred 70,000 shares of Dell stock owned one-half by him and one-half by Kim to the partnership account"

"Tom opened an account at Morgan Stanley Dean Witter"

"Holman v. Commissioner, 130 T.C. No. 12 (2008)"