Estate of Coon v. Commissioner
United States Tax Court
Petitioner's election of special use valuation for certain farm property included in decedent's estate is disallowed. Sec. 2032A(e)(6), I.R.C. 1954, requires material participation over a period of years prior to death by decedent or a member of decedent's family, and management activities of decedent's brother did not qualify under criteria set forth in sec. 20.2032A-3(e)(2), Estate Tax Regs.
1Opinion of the Court
Cohen, Judge:
In a statutory notice of deficiency dated December 30,1980, respondent determined a deficiency in the amount of $98,916.30 in estate taxes due from petitioner estate. After concessions, the sole issue for resolution is whether, during the 8-year period ending on the date of decedent Catherine E. Coon’s death, there were periods aggregating 5 or more years during which the decedent or a member of decedent’s family "materially participated” in the operation of certain farm property within the meaning of section 2032A(e)(6).1
FINDINGS OF FACT
Some of the facts have been stipulated and…
2Cases cited3 opinions
- Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Estate of Cowser v. CommissionerUnited States Tax Court · 1983
- Estate of Geiger v. CommissionerUnited States Tax Court · 1983
3Cited by36 opinions
- Estate of Gunland v. CommissionerUnited States Tax Court · 1987
- Mary Jean Martin, and John R. Fischer v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- Estate of Abell v. CommissionerUnited States Tax Court · 1984
- Estate of Maddox v. CommissionerUnited States Tax Court · 1989
- McDonald v. CommissionerUnited States Tax Court · 1987
31 more not listed; retrieve them via the Exa API.