Estate of Mary Roppolo Artall, Deceased, Jasper Artall, Betty Jo Artall Vollenweider, Ralph Artall, Co-Executors,, Petitioners

~CC.~E' / 5 5 J /`~Q lpet ft) T .C . Memo . 2008-6 7

UNITED STATES TAX COUR T

ESTATE OF MARY ROPPOLO ARTALL, DECEASED, JASPER ARTALL, CO- EXECUTOR, BETTY JO ARTALL VOLLENWEIDER, CO-EXECUTOR ; AND RALP H ARTALL, CO-EXECUTOR, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 18899-05 . Filed March 18, 2008 .

Donald A . Capretz and Lawrence D . Huter , for petitioners .

Lillian D . Brigman , for respondent .

MEMORANDUM OPINIO N

HALPERN, Judge : Respondent determined a $247,101 deficiency in Federal estate tax .

All section references are to the Internal Revenue Code in effect for November 21, 2001, the date of the death of Mar y %WED "fit -18 2004 Roppolo Artall (decedent) . All Rule references are to the Tax Court Rules of Practice and Procedure .

Some of the facts have been stipulated, and are so found .

The stipulation of facts, with accompanying exhibits, is incorporated herein by this reference . Jasper and Ralph Artall resided in Louisiana and Betty Jo Artall Vollenweider resided in Texas at the time the petition was filed .

The sole issue remaining for decision is a question of law that, recently, we answered in Estate of Farnam v . Commissioner , 130 T .C . - (2008) . The question is whether, for purposes of the liquidity test of section 2057(b)(1)(C), decedent's loans to an entity owned by her and two of her children and carrying on a trade or business are to be'treated as interests in that entity .

In Estate of Farnam we answered that question in the negative .

Petitioners have made no arguments that lead us to believe that we erred in Estate of Farnam . We rely on Estate of Farnam and hold accordingly .

Decision will be entere d under Rule 155 .