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University of Baltimore Law Review

Abstract

When pre-death estate planning is absent or ineffective, the executor of an estate consisting primarily of stock of a closely held corporation faces a problem in deriving the liquidity necessary to pay estate taxes. The problem is aggravated if the beneficiaries wish to maintain the current balance of control in the closely held corporation. As a practical guide to executors in this situation, the author discusses the provisions of the Internal Revenue Code which can help mitigate the problem.

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