The Internal Revenue Service has addressed, in a technical advice memorandum,1 the cross-referencing from the special use valuation rules2 to the passive activity rules3 in determining whether the material participation rules (on a regular, continuous and substantial basis4) were met for a farming operation after the death of the husband and before the death of the wife.5 The farm operation was conducted through a limited liability company wholly owned by a grantor trust.6
Harl, Neil E.
"Meeting the Passive Loss Requirements as a Surviving Spouse,"
Agricultural Law Digest: Vol. 20
, Article 1.
Available at: http://lib.dr.iastate.edu/aglawdigest/vol20/iss8/1