Estate of Duane B. Farnam, Deceased, Mark D. Farnam, Personal Representative, and Estate of Lois L. Farnam, Deceased, Mark D. Farnam, Personal Representative - Page 17

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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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