Gettysburg National Bank v. United States

MEMORANDUM

RAMBO, Chief Judge.

Before the court is Plaintiff’s request for a determination of the validity of its partial § 2032A election for special use valuation. The issue has been fully briefed and the matter is now ripe for disposition.

Background1

Upon their father’s death, John Lott (“John”) and M. Sheila Lott Gantz (“Sheila”) were bequeathed all of Bear Mountain Orchards, and one half of three other farms — Piney Mountain Orchards, Flicker Hill Orchards, and Emory Tuckey Tract. The other half interest of these three farms was left to their siblings, Robert C. Lott (“Robert, Jr.”) and…