The authors argue that the goals of estate and gift taxation are not served by taxing closely held businesses when the recipient of the business actively participates in its operation. Further, the authors suggest that taxing closely held businesses tends to harm capital production. The authors propose an approach to estate and gift taxation that encourages productive behavior by the recipients of wealth.

Document Type


Publication Date

Spring 1997

Publication Information

32 Real Property, Probate and Trust Journal 103-143 (1997)