All Theses, Dissertations, and Capstone Projects

Year of Award



Master of Science in Taxation (MST)


College of Business & Professional Studies

Degree Program



Business Administration


estate, market, commisioner, valuation


The impact of estate and gift taxes is a major consideration in the formation and restructuring of closely held businesses.

Estate freezing proliferated as a method of shifting appreciation in assets from older family members in high tax brackets to younger family members with lower taxable incomes on a tax-free or tax-advantaged basis. The antifreeze provisions contained in Internal Revenue Code Section 2036(c) were designed to prevent many of the alleged abuses of prior estate freezing practices. However, the Section 2036(c) restrictions were complex and difficult to administer. Subsequently, Section 2036(c) was repealed and replaced by the special valuation rules of Chapter 14 of the Internal Revenue Code, enacted by the Revenue Reconciliation Act of 1990.

This thesis will present a detailed analysis of the aforementioned special valuation rules and then will take a cross-sectional approach to scrutinize the vehicles used to retain or transfer wealth among members of closely held businesses. Outside exchanges and charitable contributions will also be considered.

The empirical research performed for this paper draws heavily on conclusions and analogies found in established court cases.

Document Type

Restricted Thesis

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Creative Commons Attribution-Noncommercial-No Derivative Works 4.0 License
This work is licensed under a Creative Commons Attribution-Noncommercial-No Derivative Works 4.0 License.


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