The Fifth Circuit on Thursday (Artall v. Commissioner, No. 09-60092 (5th Cir. Jan. 28, 2010)) joined the Eighth Circuit (Estate of Farnam v. Commissioner, 583 F.3d 581 (8th Cir. 2009)) and Tax Court (Estate of Farnam v. Commissioner, 130 T.C. No. 2 (Feb. 4, 2008); Artall v. Commissioner, T.C. Memo. 2008-67 (Mar. 18, 2008)) in holding that the § 2057 estate tax deduction of up to $675,000 for "qualified family-owned business interests" covers only equity or ownership interests, not debt interests. (Section 2057 was repealed for estates of decedents dying after December 31, 2003, but is scheduled to be reinstated in 2011.)
