Elaine owns an oceanfront condominium. For the past 10 years, Elaine has permitted each of her three children to take their families to the condo for one week each month. Elaine takes the remaining week. Looking for ways to reduce her estate tax exposure, Elaine first transfers the condo to a wholly owned, manager-managed LLC and later assigns a 25 percent LLC interest to each child. As manager of the LLC, Elaine technically controls who may use the condo and when. She and her children continue to use the property as they have in the past. Discuss the likely estate tax consequences if Elaine dies owning her 25 percent LLC interest while serving as manager of the LLC.

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