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Abstract

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.

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