For purposes of the election to defer Federal estate tax payments relative to an interest in a closely held business, an interest in a closely held business does not include:

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For the election to defer Federal estate tax payments, an interest in a closely held business generally requires that the decedent's interest in the business exceeds 20% or that the business has no more than 45 partners. A 10% interest in a partnership with 48 partners does not meet these criteria.

For Purposes of the Election to Defer Federal Estate Tax