Estate of Farnam v. Comm'r
United States Tax Court
Held: For purposes of the liquidity test of sec. 2057(b)(1)(C), I.R.C. (relating to estate tax deductions under sec. 2057(a), I.R.C., for certain qualified family-owned business interests), decedents' loans to their family-owned corporation are not treated as "interests" in the corporation.
1Opinion of the Court
OPINION
Swift, Judge:
Respondent determined deficiencies of $763,131 and $1,491,616 in the Federal estate tax of the estates of decedents Duane B. Farnam (DBF Estate) and Lois L. Farnam (llf Estate), respectively.
The issue for decision is whether, for purposes of the liquidity test of section 2057(b)(1)(C), decedents’ loans to their family-owned corporation are to be treated as “interests” in the corporation.
Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) as in effect for the dates of decedents’ deaths, and all Rule references are to the Tax Court…
2Cases cited11 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Kaiser Aluminum & Chemical Corp. v. BonjornoSupreme Court of the United States · 1990
- Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
- Fernandez v. CommissionerUnited States Tax Court · 2000
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3Cited by6 opinions
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- Estate of Artall v. CommissionerCourt of Appeals for the Fifth Circuit · 2010
- Estate of Duane B. Farnam, Mark D. Farnam, Personal Representative, and Estate of Lois L. Farnam, Mark D. Farnam, Personal Representative v. CommissionerUnited States Tax Court · 2008
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