Stovall v. Commissioner
United States Tax Court
Ps received from decedent's estate farm property qualifying for special use valuation under sec. 2032A, I.R.C. Within 15 years of decedent's death, Ps, as qualified heirs, leased the qualified real property to a coheir under a cash rental arrangement.
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Ps received from decedent's estate farm property qualifying for special use valuation under sec. 2032A, I.R.C. Within 15 years of decedent's death, Ps, as qualified heirs, leased the qualified real property to a coheir under a cash rental arrangement. Within the 15-year period following decedent's death, respondent issued a questionnaire to Ps, which they answered and returned to respondent, disclosing the cash rental of the qualified property. 1. Held, P's cash rental of the qualified property constituted a cessation of qualified use resulting in a liability for additional Federal estate tax…
1Opinion of the Court
Mary Eileen Stovall, Qualified Heiress of Estate of Mary E. Keyes, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Stovall v. Commissioner
Docket Nos. 19432-91, 19433-91, 19434-91, 19435-91, 19436-91, 19437-91, 19438-91
United States Tax Court
101 T.C. 140; 1993 U.S. Tax Ct. LEXIS 50; 101 T.C. No. 9;
July 29, 1993, Filed
Decisions will be entered for petitioners.
Ps received from decedent's estate farm property qualifying for special use valuation under sec. 2032A, I.R.C. Within 15 years of decedent's death, Ps, as qualified heirs, leased the qualified real property to a coheir…
2Cases cited16 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- Commissioner v. McCoySupreme Court of the United States · 1987
- Hays Corp. v. CommissionerUnited States Tax Court · 1963
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