-Partial repeal would exhaust resources and capital from family farmers and small business owners as they hire attorneys to pursue tax avoidance policies and incur the cost of tax related insurance plans.

-Partial repeal would encourage the wealthy to buy working farmland and allow their heirs to sell it for residential and commercial development.

-Partial repeal would establish Virginia as the primary defendant of lawsuits regarding death taxes because exemption language departs radically from the federal calculation.

-Partial repeal would drain state regulatory and enforcement resources.

-Partial repeal would encourage tax flight by those with means seeking shelter in states without a death tax.

-Tax flight carries a greater consequence with impact on income tax revenue, capital investment, charitable giving and volunteerism.

-Partial repeal with a $10 million cliff means that growing businesses will suddenly be vulnerable to this tax in the coming years as they grow.

-Partial repeal clauses for "working farms" and "closely held businesses" are so narrowly drawn that not a single business in Virginia could be identified that would be affected according to the Department of Planning and Budget in 2004.

-Governor Kaine promised to phase out the death tax and conform Virginia to federal law. Amendments made to SB 504 move us further away the WRONG way from the federal law.

-Further, the Wills, Trusts and Estates Section of the Virginia Bar Association expressed concerns regarding partial repeal legislation. They stated that partial repeal is "unusual and perhaps arbitrary."