The court of appeals found no obvious reason for the denial of the IRS's Section 2036 claim and remanded for consideration of the claim and revaluation if necessary.
5th Circuit Remands Strangi to Consider § 2036 Claim
This case is the 5th Circuit's review of the Tax Court case, Estate of Strangi v. Commissioner, 115 T.C. No. 35 (U.S. Tax Ct. Nov. 30, 2000), abstracted in the January 2001 BVU.