(question of whether decedent's transfer of assets from marital fund to family limited partnership constituted a completed transfer for gift tax purposes was directly at issue in the estate tax case and in the gift tax case; decedent did not complete transfer as claimed - because attempted transfer to FLP was not completed and did not constitute a gift, a gift tax liability attributable to the transfer did not arise, and no gift tax deduction allowed; estate tax deficiency upheld; decision affirms T.C. Memo. 2007-370).