Estate of Artall v. Commissioner

JERRY E. SMITH, Circuit Judge:

The Commissioner of Internal Revenue (“the IRS”) disallowed a “qualified family-owned business interest” estate tax deduction to Mary Artall’s estate. Upon petition, the Tax Court found for the IRS. We affirm.

I

A. The Qualified Family-Owned Business Interest Deduction

This case turns on the interpretation of § 2057 of the Internal Revenue Code, 26 U.S.C. § 2057, which provides an estate tax deduction for certain “qualified family-owned business interests” (“QFOBI’s”). 1 As its name suggests, the QFOBI deduction allows an estate to deduct the value of a decedent’s…