- 4 - 2000 (the estate tax return). On Schedule T of the estate tax return, the estate claimed a deduction under section 2057 of $675,000. The estate reported qualified family-owned business interests (QFOBIs) valued at $2,870,933, consisting of decedent’s interest in Keeton Corrections valued at $1,285,531 and his interest in NSP valued at $1,585,402. Pursuant to section 2057(b)(1)(B), the executor elected the application of section 2057 and filed the agreement referred to in section 2057(h). Respondent issued his notice of deficiency on August 26, 2003. In his notice of deficiency, respondent, among other adjustments, disallowed the family-owned business deduction in its entirety. Discussion I. Section 2057 Section 2057(a) provides an estate tax deduction for QFOBIs effective for estates of decedents dying after December 31, 1997. Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 502(c), 111 Stat. 852. A QFOBI includes an interest as a proprietor in a business carried on as a proprietorship or an interest in an entity carrying on a business if at least 50 percent of the entity is owned, directly or indirectly, by the decedent or a member of the decedent's family. Sec. 2057(e)(1). If an estate qualifies for and elects to take the deduction, up to $675,000 of the adjusted value of QFOBIs may be deducted from the value of aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011