Action by the Court of Appeals for the Federal Circuit in late 1998 in Rinaldi v. United States, affirming a 1997 U.S. Court of Federal Claims case has focused attention on an approach to disposing of an interest in a closely-held business that can render the property ineligible for qualified terminable interest property (QTIP) treatment. The problem related to a will provision giving a son the right to purchase stock in a closely-held corporation at less than fair market value. The result was ineligibility for the QTIP election.
"Care Needed In Drafting QTIP Provisions And In Post-Death Planning To Repair Deficiencies,"
Agricultural Law Digest: Vol. 10
, Article 1.
Available at: http://lib.dr.iastate.edu/aglawdigest/vol10/iss11/1