Sequeira v. Commissioner
United States Tax Court
P elected to value four parcels of land, owned by decedent at the time of death, under the special use valuation provision of sec. 2032A, I.R.C. The election was made on the original timely filed Federal estate tax return filed for the estate. A recapture agreement was also attached.
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P elected to value four parcels of land, owned by decedent at the time of death, under the special use valuation provision of sec. 2032A, I.R.C. The election was made on the original timely filed Federal estate tax return filed for the estate. A recapture agreement was also attached. R determined that P's election was invalid, arguing that P submitted a notice of election and recapture agreement not containing all of the information required under secs. 20.2032A-8(a) (3) and 20.2032A-4, Estate Tax Regs. 1. Held, P failed to "substantially comply" with the regulations under sec. 2032A, I.R.C.,…
1Opinion of the Court
ESTATE OF JOSEPH A. SEQUEIRA, DECEASED, GEORGE SEQUEIRA AND ALBERT SEQUEIRA, EXECUTORS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sequeira v. Commissioner
Docket No. 16264-91.
United States Tax Court
T.C. Memo 1995-450; 1995 Tax Ct. Memo LEXIS 450; 70 T.C.M. (CCH) 761;
September 21, 1995, Filed
Decision will be entered under Rule 155.
P elected to value four parcels of land, owned by decedent at the time of death, under the special use valuation provision of sec. 2032A, I.R.C. The election was made on the original timely filed Federal estate tax return filed for the estate. A…
2Cases cited11 opinions
- Taylor v. CommissionerUnited States Tax Court · 1977
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Dunavant v. CommissionerUnited States Tax Court · 1974
- Estate of Gunland v. CommissionerUnited States Tax Court · 1987
- Beryl P. Williamson v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1992
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