At the encouragement of her estate planner, Rita contributes $40 million of marketable securities to a limited partnership. She takes back a 99 percent interest as limited partner, and a 50 percent interest in an LLC that is formed to serve as the general partner. The other 50 percent interest of the LLC is held by her two children in equal shares. The partnership agreement calls for the net investment income of the entity to be distributed on an annual basis. The estate planner documents the following purposes for forming the entity: (1) creation of a vehicle for joint investment of family assets; (2) protection of family assets from potential claims of spouses of descendants and other would-be creditors; and (3) transfer tax savings. Upon Rita's death four years later, the estate values her partnership interests at 55 percent of net asset value, based on discounts for lack of marketability and lack of control. Discuss the prospects of the partnership assets being included in Rita's gross estate under 2036(a).