Estate of McAlpine v. Commissioner
United States Tax Court
P elected to value a ranch owned by decedent at the time of his death under the special use valuation provision of sec. 2032A of the I.R.C. of 1954, as amended. The election was made on the original timely filed estate tax return filed for the estate and a recapture agreement was also attached.
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P elected to value a ranch owned by decedent at the time of his death under the special use valuation provision of sec. 2032A of the I.R.C. of 1954, as amended. The election was made on the original timely filed estate tax return filed for the estate and a recapture agreement was also attached. The election and agreement were signed by the executrix of the estate but not by any of decedent's three grandchildren who were the beneficiaries of a trust to which the ranch was devised under the will. An amended estate tax return with an amended election and recapture agreement were filed within 90…
1Opinion of the Court
OPINION
DRENNEN, Judge:
This case was submitted fully stipulated and the facts as stipulated are so found. Respondent determined a deficiency in the estate tax of the Estate of Malcolm McAlpine, Jr., in the amount of $333,363.24, subject to credits for payments of State death taxes.
Petitioner is the Estate of Malcolm McAlpine, Jr., deceased. Geraldine McAlpine and Jocelyn McAlpine Greeman are co-independent executrixes.
Malcolm McAlpine, Jr. (hereinafter referred to as decedent), died testate on February 25, 1984. He was a citizen of the United States and a resident of Texas at the time of his…
2Cases cited7 opinions
- Lucille Prussner, as of the Estate of Aileen E. Pfeifer v. United StatesCourt of Appeals for the Seventh Circuit · 1990
- Estate of Gunland v. CommissionerUnited States Tax Court · 1987
- Estate of Maddox v. CommissionerUnited States Tax Court · 1989
- McDonald v. CommissionerUnited States Tax Court · 1987
- Estate of Strickland v. CommissionerUnited States Tax Court · 1989
2 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Elena Lea Morgan Weschenfelder & Frederick Burkhart Weschenfelder v. CommissionerUnited States Tax Court · 2019
- Estate of McAlpine v. CommissionerUnited States Tax Court · 1991
- Sequeira v. CommissionerUnited States Tax Court · 1995