Legal Opinion
Beryl P. Williamson v. Commissioner Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided September 14, 1992No. 89-70506PublishedCited by 30 opinions
1Opinion of the Court
TANG, Circuit Judge:
Beryl Williamson inherited farm land from his mother in 1983. In the estate tax return, Williamson elected the special use valuation for the property provided by 26 *1527U.S.C. § 2032A. Williamson subsequently leased the farm to his nephew for a fixed, semi-annual cash payment. In 1987, the Internal Revenue Service (“IRS”) issued a Notice of Deficiency to Williamson, asserting that the cash lease rendered the land ineligible for special use valuation. The Tax Court agreed with the IRS. Williamson appeals. We affirm.
BACKGROUND
A. Statutory Framework
Generally, for purposes of…
2Cases cited18 opinions
- Immigration & Naturalization Service v. Cardoza-FonsecaSupreme Court of the United States · 1987
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Pavelic & LeFlore v. Marvel Entertainment Group, Div. of Cadence Industries Corp.Supreme Court of the United States · 1990
- Badaracco v. CommissionerSupreme Court of the United States · 1984
- United States v. Mohammad Reza MehrmaneshCourt of Appeals for the Ninth Circuit · 1982
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3Cited by30 opinions
- Neama El Sayed Ramadan Gaser Hesham El Gendy v. Alberto R. Gonzales, Attorney GeneralCourt of Appeals for the Ninth Circuit · 2007
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- LeFever v. CommissionerCourt of Appeals for the Tenth Circuit · 1996
- Richard A. Cramer Alice D. Cramer Warren K. Boynton Susi M. Boynton Kevin P. Monaghan Dina A. Monaghan v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- Lawinger v. Comm'rUnited States Tax Court · 1994
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