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ESTATE OF FARNAM v. COMMISSIONER

No. 3575-06.

130 T.C. 34 (2008)

ESTATE OF DUANE B. FARNAM, DECEASED, MARK D. FARNAM, PERSONAL REPRESENTATIVE, AND ESTATE OF LOIS L. FARNAM, DECEASED, MARK D. FARNAM, PERSONAL REPRESENTATIVE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 4, 2008.

Attorney(s) appearing for the Case

Sue Ann Nelson and Robert J. Stuart, for petitioners. Blaine Holiday, for respondent.

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...

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