130 T.C. No. 2
UNITED STATES TAX COURT
ESTATE OF DUANE B. FARNAM, DECEASED, MARK D. FARNAM, PERSONAL
REPRESENTATIVE, AND ESTATE OF LOIS L. FARNAM, DECEASED, MARK D.
FARNAM, PERSONAL REPRESENTATIVE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3575-06. Filed February 4, 2008.
Held: For purposes of the liquidity test of sec.
2057(b)(1)(C), I.R.C. (relating to estate tax
deductions under sec. 2057(a), I.R.C., for certain
qualified family-owned business interests), decedents’
loans to their family-owned corporation are not treated
as “interests” in the corporation.
Sue Ann Nelson and Robert J. Stuart, for petitioners.
Blaine Holiday, for respondent.
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Last modified: March 27, 2008