Lucas v. United States

ANDERSON, Circuit Judge:

In this federal estate tax case, the government determined that the Estate of Charles R. Lucas (the Estate) was not entitled to “special use valuation” of certain family farm property pursuant to section 2032A of the Internal Revenue Code. See 26 U.S.C. § 2032A. The first issue on appeal is whether the Estate’s initial effort to elect special use valuation was sufficient to constitute “substantial compliance” with the applicable regulations, thereby entitling the Estate to perfect its election upon notice from the I.R.S. that the original election was deficient. See 26…