Legal Opinion

Estate of Heffley v. Commissioner

United States Tax Court

Decided August 11, 1987No. Docket No. 3201-85PublishedCited by 9 opinions

From 1976 until D's death in 1981, D's farm was leased to individuals who were not members of her family. The income received by D was fixed under such leases and was not dependent on crop production on the farm. Such leases did not call for D, or anyone acting on her behalf, to render services, and D was not involved in the management decisions associated with the operation of the farm.

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From 1976 until D's death in 1981, D's farm was leased to individuals who were not members of her family. The income received by D was fixed under such leases and was not dependent on crop production on the farm. Such leases did not call for D, or anyone acting on her behalf, to render services, and D was not involved in the management decisions associated with the operation of the farm. Held: 1. The farm was not being used for a qualified use within the meaning of sec. 2032A(b)(2), I.R.C. 1954, and neither D nor a member of her family materially participated in the operation of the farm;…

1Opinion of the Court

SIMPSON, Judge:

The Commissioner determined a deficiency of $84,373.47 in the petitioner’s Federal estate tax. After concessions, the issues for our decision Eire: (1) Whether the petitioner is entitled to value real property in which the decedent held an interest at her death by use of the special use valuation provisions of section 2032A, Internal Revenue Code of 1954;1 and (2) whether the petitioner is entitled to pay interest on any deficiency in Federal estate tax at the reduced rate provided in section 6601(j).

FINDINGS OF FACT

Some of the facts have been stipulated, and those facts are so…

2Cases cited15 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. LTV Corp. v. CommissionerUnited States Tax Court · 1975
  3. Estate of Ralph D. Cowser, Deceased, Patricia Ann Tucker v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1984
  4. Estate of Baumgardner v. CommissionerUnited States Tax Court · 1985
  5. Estate of Bahr v. CommissionerUnited States Tax Court · 1977

10 more not listed; retrieve them via the Exa API.

3Cited by9 opinions

  1. Lawinger v. Comm'rUnited States Tax Court · 1994
  2. LeFever v. CommissionerUnited States Tax Court · 1994
  3. Estate of Bell v. CommissionerUnited States Tax Court · 1989
  4. Williamson v. CommissionerUnited States Tax Court · 1989
  5. Estate of Bell v. CommissionerUnited States Tax Court · 1989

4 more not listed; retrieve them via the Exa API.

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