In recent years, few issues have been more perplexing in farm estate and business planning than the circumstances under which activities of an agent, such as a farm manager, are imputed to the property owner as principal. Enactment of 15-year installment payment of federal estate tax and special use valuation in 1976 and the family owned business exclusion in 19974 (which was converted from an exclusion to a deduction in 1998) have added to the urgency of the problem.