In answering the research questions cite primary authority {Code Section, Treasury Regulation, Revenue Procedure}. You may use secondary authorities to conduct your research, but you must cite primary authority in your answer. RESEARCH QU ESTIONS D has three assets which make up the vast majority of D's estate: {i} D's house [real estate} valued at $18,000,000, with an adjusted basis of $1,000,000, lii}I an operating business valued at $32,000,000, and {iii} a bank account with $10,000,000 cash. D has already used the majority of D's unied credit. 0 would like to transfer these assets to the next generation at as low of a transfer tax cost as possible. D trusts the next generation [his four children} and is not opposed to ceding nancial control to them, however, as D has superior working knowledge of the business, D would like to maintain some form of operational control at least until D's children are ready to take over the business, and of course 0 needs a place to live. D has been told by one of D's nancial advisors that if he transfers so me or all of his assets to a Partnership and then transfersfgifts nonvoting ("limited\") partnership interests to D's children, D will receive a transfer tax discount for "lack of marketability\" [difcult to sell} and "lack of control\" {if recipient can't vote their shares or is in a minority position}, D has also been told that there is a possibility of reducing transfer taxes by transferring just a remainder interest to a trust a retaining an income interest for life. Questions: 1. Is there supporffauthority for D's advisor's suggestion that D can receive a transfer tax discount [for marketability and control} if D transfers {gifts} limited partnership interests [nonvoting} to his children? [YES or ND and citation}