Legal Opinion
Estate of Farnam v. Commissioner
Court of Appeals for the Eighth Circuit
Decided October 8, 2009No. 08-3196PublishedCited by 20 opinions
1Opinion of the Court
LIMBAUGH, District Judge.
This is an estate tax case in which the single issue is whether certain unsecured loans made by the decedents to a family-owned corporation constitute “interests” in the corporation, as that term is used to determine the estates’ eligibility for “qualified family-owned business interest” (QFOBI) deductions under I.R.C. § 2057(a). The Tax Court, hearing the case on a stipulated record, disallowed the deductions, holding that an “interest” in a corporation is necessarily limited to an equity or ownership interest, and does not include a creditor’s “interest” in an…
2Cases cited6 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
- Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
- Theresa E. Bartman v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2006
- Flahertys Arden Bowl, Inc. v. CommissionerUnited States Tax Court · 2000
1 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Owner-Operator Independent Drivers Ass'n v. Supervalu, Inc.Court of Appeals for the Eighth Circuit · 2011
- Center for Special Needs Trust Administration, Inc. v. OlsonCourt of Appeals for the Eighth Circuit · 2012
- Missouri v. PORTFOLIO RECOVERY ASSOCIATES, INC.District Court, E.D. Missouri · 2010
- Hays v. COMMUNICATION TECHNOLOGIES, INC.District Court, S.D. Iowa · 2010
- Christians v. KemPharm, Inc.District Court, S.D. Iowa · 2017
15 more not listed; retrieve them via the Exa API.