Various anesthetic techniques can be utilized for SFLP, including monitor anesthetic care, sedation, regional anesthesia, and general anesthesia.
The aim of our study is to determine the effects of preoperative nifedipine use in normotensive mothers on the incidence of maternal hypotension during SFLP under epidural anesthesia.
First, it contends that the Tax Court erred in holding that S retained (1) "possession or enjoyment" of the property he transferred to SFLP or (2) the right to designate who would possess or enjoy it.
The core of E's argument on appeal is that the Tax Court erred in concluding that S retained possession or enjoyment of the assets he transferred to SFLP. Sec.
Ninety-eight percent ($9,876,929) of the decedent's estate was transferred to the SFLP. In consideration of the transfer, the decedent received 99% of the interest in the limited partnership.
Subsequent to the formation of the SFLP, the partnership paid for the decedent's health care and, after his death, paid for his funeral, estate administration expenses, and debts.
28, 1998, the Sendas transferred 28,500 shares of MCI WorldCom from their joint brokerage accounts to SFLP I in exchange for their GP and LP interests.
SFLP II had a similar structure; the Sendas collectively owned a 1% GP interest and a 98.97% LP interest, while their minor children owned the remaining .03% LP interest through trusts.
Following the formation of SFLP, various distributions were made to S's estate and to his children.
The IRS challenged SFLP's existence, arguing that, under the business-purpose and economic-substance doctrines, it should be disregarded in valuing S's estate.