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STRANGI v. C.I.R.

No. 03-60992.

417 F.3d 468 (2005)

Albert STRANGI, Deceased, Rosalie Gulig, Independent Executrix, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

July 15, 2005.

Attorney(s) appearing for the Case

Norman Arthur Lofgren (argued), George Tomas Rhodus, Michael C. Kelsheimer, Looper, Reed & McGraw, Dallas, TX, for Petitioner-Appellant.

Michael J. Haungs (argued), U.S. Dept. of Justice, Tax Div., Jonathan S. Cohen, U.S. Dept. of Justice, Tax Div., Appellate Section, Eileen J. O'Connor, Asst. Atty. Gen., U.S. Dept. of Justice, Emily A. Parker, I.R.S., Washington, DC, for Respondent-Appellee.

Milford B. Hatcher, Jr., Jones Day, Atlanta, GA, for American College of Trust and Estate Counsel, Amicus Curiae.

Before REAVLEY, JOLLY and PRADO, Circuit Judges.

E. GRADY JOLLY, Circuit Judge:

This case, which comes before us now for a second time, involves an assessment by the Commissioner of Internal Revenue of an estate tax deficiency against the Estate of Albert Strangi. Initially, the Tax Court held for the Estate. However, we remanded to the Tax Court, which reversed its prior holding and decided the case under I.R.C. § 2036(a). Section 2036(a) provides that transferred assets of which the decedent retained de facto...

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