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Also, as previously noted, language connoting equity
ownership is used pervasively in section 2057, and we conclude
that the section 2057(e)(1)(B) definition of an “interest in an
entity”, for purposes of the qualified family-owned business
interest deduction, is limited to equity ownership interests.
For the reasons stated, we conclude that the FGP loan
interests held by decedents (directly and indirectly through
their controlled partnerships) are not to be treated as QFOBIs
for purposes of section 2057 and thus that the QFOBI deductions
petitioners claimed are not allowable.
Other arguments made by the parties and not discussed herein
we have considered and rejected as without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: March 27, 2008