- 2 -
Roppolo Artall (decedent). All Rule references are to the Tax
Court Rules of Practice and Procedure.
Some of the facts have been stipulated, and are so found.
The stipulation of facts, with accompanying exhibits, is
incorporated herein by this reference. Jasper and Ralph Artall
resided in Louisiana and Betty Jo Artall Vollenweider resided in
Texas at the time the petition was filed.
The sole issue remaining for decision is a question of law
that, recently, we answered in Estate of Farnam v. Commissioner,
130 T.C. __ (2008). The question is whether, for purposes of the
liquidity test of section 2057(b)(1)(C), decedent’s loans to an
entity owned by her and two of her children and carrying on a
trade or business are to be treated as interests in that entity.
In Estate of Farnam we answered that question in the negative.
Petitioners have made no arguments that lead us to believe that
we erred in Estate of Farnam. We rely on Estate of Farnam and
hold accordingly.
Decision will be entered
under Rule 155.
Page: Previous 1 2
Last modified: March 27, 2008