United States Fifth Circuit

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Estate of Artall v. Comm'r. of Int'l. Rev., 09-60092

In the taxpayer's appeal from the tax court's approval of the IRS Commissioner's disallowance of a "qualified family-owned business interest" estate tax deduction to the taxpayer estate, the tax court's order is affirmed where the "qualified family-owned business interest" deduction of 26 U.S.C. section 2057 is available for an estate's qualifying equity or ownership interests but not for debt interests such as loans receivable.

Appellate Information

  • Decided 01/29/2010
  • Published 01/29/2010


  • JERRY E. SMITH, Circuit Judge:, Before JONES, Chief Judge, SMITH and DeMOSS, Circuit Judges.


  • United States Fifth Circuit