At issue is the transferral of assets for an interest in partnership (operated by decedent's son) was a "bona fide" sale or not, thus incurring Section 2036 consideration.
Kimbell v. US
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5th Circuit Holds LLC and Limited Partnership Transfers Were Bona Fide
In this estate tax case, the 5th Circuit vacated and remanded the district court’s granting of summary judgment to the Commissioner on the grounds that the transfer under IRC §2036 was a bona fide sale for full and adequate consideration.