Estate of Duane B. Farnam, Deceased, Mark D. Farnam, Personal Representative, and Estate of Lois L. Farnam, Deceased, Mark D. Farnam, Personal Representative - Page 16

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                              (A) an interest as a proprietor in a                    
                         trade or business carried on as a                            
                              (B) an interest as a partner in a                       
                         partnership carrying on a trade or business                  
                         * * *                                                        
                         *    *    *    *    *    *    *                              
                              (C) stock in a corporation carrying on a                
                         trade or business * * *.  [Emphasis added.]                  

               Respondent acknowledges the relationship between section               
          6166 and section 2057, but respondent argues that the limitations           
          in section 6166 to equity ownership interests support                       
          respondent’s position that section 2057(e)(1)(B) should be                  
          construed in a parallel manner to limit the QFOBI to an equity              
          ownership interest.                                                         
               Our holding herein is based largely on the close proximity             
          of the language “interest in an entity” in section 2057(e)(1)(B)            
          to the explicit equity ownership language of section                        
          2057(e)(1)(B)(i) and (ii).  We find it illogical to divorce the             
          equity ownership requirements of section 2057(e)(1)(B)(i) and               
          (ii) from the immediately preceding language.  As we read the               
          statute, the “interest in an entity” language of section                    
          2057(e)(1)(B) encompasses, or embraces, or is limited to, only              
          the type of interests (i.e., to equity ownership interests) that            
          is described in the rest of the very same sentence (i.e., in the            
          immediately following clauses of section 2057(e)(1)(B)).                    

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