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
Dawson, Judge:
These cases were assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(3)2 and Rules 180, 181, and 182. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Couvillion, Special Trial Judge:
Respondent determined a deficiency of $2,861.87 in additional Federal estate tax against petitioner Mary Eileen Stovall, a qualified heir who received farm property subject to a section 2032A special use valuation. Respondent also determined a deficiency of $6,595.29 against each of the…
2Cases cited15 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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