1. James owns all of the common stock in a software company he founded eight years ago, which is valued at $9 million. His estate, which includes the value of his company, is worth $10.8 million, and is growing rapidly. James wants to remove a portion of the business and its appreciation from his gross estate, and he wants to share the future appreciation of his company with his three children who work in the business. James is hesitant to gift some of his stock to his children because he needs the income until he is ready to retire, and he also does not want to cede control of the management of the company to his children. What planning technique might accomplish Jamess objectives?

1. A private annuity
2. A partnership freeze
3. A preferred stock recapitalization
4. A split-interest purchase of the business