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.



To view the content in your browser, please download Adobe Reader or, alternately,
you may Download the file to your hard drive.

NOTE: The latest versions of Adobe Reader do not support viewing PDF files within Firefox on Mac OS and if you are using a modern (Intel) Mac, there is no official plugin for viewing PDF files within the browser window.