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interest therein (i.e., only an interest “as a proprietor”).
Section 2057(e)(1)(A) provides as follows:
SEC. 2057. FAMILY-OWNED BUSINESS INTERESTS.
(e) Qualified Family-Owned Business Interest.--
(1) In general.--For purposes of this
section, the term “qualified family-owned business
interest” means --
(A) an interest as a proprietor in a
trade or business carried on as a
proprietorship, * * * [Emphasis added.]
Under section 2057(e)(1)(B) relating to family-owned
corporations and partnerships, no such express equity limitation
on the definition of an interest in a family-owned entity is
stated, and reference is made, in the flush language, only to “an
interest in” a family-owned entity. However, clauses (i) and
(ii) of section 2057(e)(1)(B) immediately go on to require
alternative 50-, 70-, and 90- percent family “ownership” in the
entity–-the so-called family ownership test.
Section 2057(e)(1)(B) provides as follows:
SEC. 2057. FAMILY-OWNED BUSINESS INTERESTS.
(e) Qualified Family-Owned Business Interest.--
(1) In general.--For purposes of this
section, the term “qualified family-owned business
interest” means--
* * * * * * *
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Last modified: March 27, 2008