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Abstract

For several years, the rules governing the cash rental of land to a family-owned entity for purposes of 15-year installment payment of federal estate tax,1 the family-owned business deduction2 and special use valuation3 have been developed and refined with distinctive differences among the three provisions for which guidance is often sought. A private letter ruling, released in May of 2005, has addressed the availability of the three provisions in the context of a unique fact situation4 and, in the process, has introduced some confusion into the fairly clear guidance in existence.

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