An Attempt to Legislate?

5 Pages Posted: 3 Oct 2007 Last revised: 24 Sep 2009

See all articles by Wendy C. Gerzog

Wendy C. Gerzog

University of Baltimore - School of Law


The Tax Court held in Roski that the government's imposition of certain pre-requisites for closely held businesses and farms to seek estate tax relief was an attempt by it to legislate. Was it? Within the context of closing the tax gap, it may not be.

Keywords: estate tax, Roski, closely held business, farm, section 6166, lien, tax gap

Suggested Citation

Gerzog, Wendy C., An Attempt to Legislate?. Tax Notes, Vol. 117, No. 1, 2007. Available at SSRN:

Wendy C. Gerzog (Contact Author)

University of Baltimore - School of Law ( email )

1420 N. Charles Street
Baltimore, MD 21218
United States
410-837-4522 (Phone)

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