Estate of James U. Thompson, Deceased Susan T. Taylor, Personal Representative v. Commissioner of Internal Revenue

K.K. HALL, Circuit Judge.

The estate of James U. Thompson (“decedent”), by its personal representative, Susan T. Taylor, daughter of the decedent, appeals the United States Tax Court’s decision holding family farming property ineligible for the special use valuation provided by section 2032A of the Internal Revenue Code of 1954, 26 U.S.C. § 2032A. The Tax Court sustained the Internal Revenue Service’s (“IRS”) determination of a deficiency in federal estate taxes in the amount of $500,267. Because the denial of the special use valuation to decedent’s estate is not mandated by statute itself and…