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In the Estate of Christiansen v. Commissioner case, the decedent, who died in April 2001, left all property to her only child H through will that anticipated disclaimer and H disclaimed a portion of the gross estate valued at over $6,350,000. The will provided that 75% of the disclaimed portion would pass to a charitable foundation and 25% would pass to 20-year charitable lead annuity trust to pay the annuity to the foundation. H did not disclaim the contingent remainder interest in the property passing to the trust; the estate claimed deductions for values of property passing to trust to the extent of present value of annuity interest, and of property passing to the foundation. The IRS determined a higher value of the estate than reported on the return and disallowed the deductions for...
In the Estate of Farnam case, which involved deficiencies in the Federal estate tax of the estates of decedents, the Tax Court held for purposes of the liquidity test for Section 2057(b)(1)(C), relating to estate tax deductions under Section 2057(a), for certain qualified family-owned business interests, decedents' loans to their family-owned corporation are not treated as interests in the corporation.
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