Legal Opinion

Estate of Coon v. Commissioner

United States Tax Court

Decided September 22, 1983No. Docket No. 5758-81PublishedCited by 36 opinions

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

  1. Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
  2. Estate of Cowser v. CommissionerUnited States Tax Court · 1983
  3. Estate of Geiger v. CommissionerUnited States Tax Court · 1983

3Cited by36 opinions

  1. Estate of Gunland v. CommissionerUnited States Tax Court · 1987
  2. Mary Jean Martin, and John R. Fischer v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
  3. Estate of Abell v. CommissionerUnited States Tax Court · 1984
  4. Estate of Maddox v. CommissionerUnited States Tax Court · 1989
  5. McDonald v. CommissionerUnited States Tax Court · 1987

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