Question: Code Sec. 2036(a) states that property which the decedent has irrevocably transferred (for less than full and adequate consideration in money or moneys worth), but

Code Sec. 2036(a) states that property which the decedent has irrevocably transferred (for less than full and adequate consideration in money or moneys worth), but retained the right to use, possess or enjoy, is included in his or her gross estate. Millicent, the general partner, transfers property to a FLP, including $300,000 worth of securities. Her income outside of the partnership is insufficient to provide for her support. Millicent continues to collect the income from the securities and deposit it in her own account.

The IRS would successfully attack the existence of this FLP based on the commingling of partnership funds with partners personal funds.
		The IRS would successfully attack the existence of this FLP because of its testamentary flavor.
		The IRS would successfully attack the existence of this FLP because Millicent has few assets of her own on which to live.
		Two of the above.

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