- 2 - OPINION SWIFT, Judge: Respondent determined deficiencies of $763,131 and $1,491,616 in the Federal estate tax of the estates of decedents Duane B. Farnam (DBF Estate) and Lois L. Farnam (LLF Estate), respectively. The issue for decision is whether, for purposes of the liquidity test of section 2057(b)(1)(C), decedents’ loans to their family-owned corporation are to be treated as “interests” in the corporation. Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) as in effect for the dates of decedents’ deaths, and all Rule references are to the Tax Court Rules of Practice and Procedure.1 Background The facts of this case have been submitted fully stipulated under Rule 122 and are so found. At the times of their deaths, decedents Duane B. Farnam and Lois L. Farnam were residents of Otter Tail County, Minnesota. At the time of filing the petition, decedents’ estates’ personal representative resided in Fargo, North Dakota. 1 Although decedents died in different years--2001 and 2003--the relevant Code provisions for both years are in all material respects the same.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008