Roski Case Analyzed

Prof. Wendy Gerzog (Professor of Law, University of Baltimore School of Law) has recently posted her article entitled An Attempt to Legislate? on SSRN.

Here is the abstract of her article:

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?

Prof. Gerzog's article also appears in 117 Tax Notes 59 (Oct. 1, 2007).