As has been reported since the 1997 enactment of the family-owned business deduction and the substantial revisions in 1998, many of the provisions in the statute were drawn from special use valuation including the provision on liens to secure the payment of any recapture tax. Unfortunately, the problem with liens under the family-owned business deduction (FOBD) is substantially more involved than the lien on land for purposes of special use valuation.



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