Estate of Duane B. Farnam, Deceased, Mark D. Farnam, Personal Representative, and Estate of Lois L. Farnam, Deceased, Mark D. Farnam, Personal Representative - Page 1















                                   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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