COHEN, Judge:
On December 1, 1998, respondent determined a $2,545,826 deficiency in the Federal estate tax of the Estate of Albert Strangi, Rosalie Gulig, independent executrix. In the alternative, respondent determined a Federal gift tax deficiency of $1,629,947.
After concessions by the parties, the issues for decision are (alternatively): (1) Whether the Strangi Family Limited Partnership (SFLP) should be disregarded for Federal tax purposes because...
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