- 9 - (2) Maximum deduction.--The deduction allowed by this section shall not exceed $675,000. Generally, under section 2057(b)(1)(C), for an estate to qualify for a QFOBI deduction, the value of the QFOBIs owned by a decedent at the time of death must exceed 50 percent of the total value of the decedent’s adjusted gross estate--the so-called 50- percent liquidity test. Section 2057(b)(1)(C) provides as follows: SEC. 2057. FAMILY-OWNED BUSINESS INTERESTS. (b) Estates to Which Section Applies.-- (1) In general.--This section shall apply to an estate if-- * * * * * * * (C) the sum of-- (i) the adjusted value of the qualified family-owned business interests described in paragraph (2), plus (ii) the amount of the gifts of such interests determined under paragraph (3), exceeds 50 percent of the adjusted gross estate * * * Under section 2057(e)(1), definitional provisions are provided, and it is expressly stated in subparagraph (A) that a QFOBI with regard to a sole proprietorship means only an equityPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: March 27, 2008