Estate of Ralph D. Cowser, Deceased, Patricia Ann Tucker v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
1Opinion of the Court
HARLINGTON WOOD, Jr., Circuit Judge.
Ralph D. Cowser died on March 15, 1978, leaving no surviving descendants. He devised his family farm to his deceased wife’s grandniece and her husband, Patricia and Hartley Tucker. Patricia Tucker, as executrix of Ralph Cowser’s estate, attempted to invoke the special use valuation provisions of section 2032A of the Internal Revenue Code, 26 U.S.C. § 2032A (1976). The Internal Revenue Service found that the grandniece was not a qualified heir, and assessed a $71,430.88 federal estate tax deficiency. The Tax Court, 80 T.C. 783, upheld the determination of…
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