From David A. Handler of Kirkland & Ellis in Chicago we have this report on the latest development in the Tax Court's understanding of the Internal Revenue Code Section 2036(a): On March 15, the court issued a decision in Estate of Wayne C. Bongard v. Comm'r, 124 T.C. No. 8; No. 6141-03, finding that a decedent hadn't transferred property to his family partnership “in a bona fide sale for an adequate consideration,” and that he'd retained an “implied” beneficial enjoyment of
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