Estate of Duane B. Farnam, Deceased, Mark D. Farnam, Personal Representative, and Estate of Lois L. Farnam, Deceased, Mark D. Farnam, Personal Representative - Page 13

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          2057(b)(1)(C)) will be taken into account indicates that no such            
          limitation was intended and therefore that “loan” interests                 
          should be taken into account.  Petitioners cite the proposition             
          that “where a statute, with reference to one subject contains a             
          given provision, the omission of such provision from a similar              
          statute concerning a related subject is significant to show that            
          a different intention existed”.  2B Singer, Sutherland Statutory            
          Construction, sec. 51.02, at 199-201 (6th ed. 2000); see also               
          United States v. Lamere, 980 F.2d 506, 513 (8th Cir. 1992)                  
          (“Where language is included in one section of a statute but                
          omitted in another section of the same statute, it is generally             
          presumed that the disparate inclusion and exclusion * * * [were]            
          done intentionally and purposely.”); Flahertys Arden Bowl, Inc.             
          v. Commissioner, 115 T.C. 269, 274 (2000), affd. 271 F.3d 763               
          (8th Cir. 2001) (per curiam).                                               
               Petitioners also note that section 2057 contains a number of           
          references to “any” interest in a qualified family-owned                    
          business, suggesting to petitioners that the reference in section           
          2057(e)(1)(B) to “an” interest is not to be limited to just an              
          “equity” interest.  See sec. 2057(e)(2)(A) (“any” interest in a             
          trade or business); id. subpar. (B) (“any” interest in an                   
          entity); id. subpar. (C) (“any” interest in a trade or business).           
               We note that no regulations have been promulgated under                
          section 2057.                                                               

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