Estate of Sherrod v. Commissioner
United States Tax Court
At death, decedent was beneficial owner of 1,478 acres of land. During the last 25 years of his life, 1,108 acres were in timber, 270 acres in row crops, and 100 acres in pasture. All of it was under exclusive management and control of decedent until 5 years before his death when he placed it in a revocable living trust. Thereafter, until his death, management and control were exercised by decedent's son, who was one of the trustees.
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At death, decedent was beneficial owner of 1,478 acres of land. During the last 25 years of his life, 1,108 acres were in timber, 270 acres in row crops, and 100 acres in pasture. All of it was under exclusive management and control of decedent until 5 years before his death when he placed it in a revocable living trust. Thereafter, until his death, management and control were exercised by decedent's son, who was one of the trustees. Management included (1) the negotiation of annual rental agreements on the crop and pasture lands, (2) contact from time to time with tenants to check their…
1Opinion of the Court
Shields, Judge:
Respondent determined a deficiency of $170,693.08 in the Federal estate tax due from the Estate of H. Floyd Sherrod. After concessions, the issues remaining for decision are: (1) Does the estate qualify for special use valuation under section 2032A1 for certain land; (2) does the Tax Court have jurisdiction to review respondent’s determination that the estate does not qualify to pay the estate tax in installments as provided in sections 6166 and 6166A; and (3) if the Tax Court has such jurisdiction, does the estate so qualify?
FINDINGS OF FACT
Some of the facts have been…
2Cases cited5 opinions
- Breman v. CommissionerUnited States Tax Court · 1976
- Estate of Young v. CommissionerUnited States Tax Court · 1983
- Medeiros v. CommissionerUnited States Tax Court · 1981
- Estate of Cowser v. CommissionerUnited States Tax Court · 1983
- Estate of Geiger v. CommissionerUnited States Tax Court · 1983
3Cited by25 opinions
- Estate of Gardner v. CommissionerUnited States Tax Court · 1984
- Estate of H. Floyd Sherrod, H. Floyd Sherrod, Jr. And Estalee Sherrod Sandlin, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Estate of Abell v. CommissionerUnited States Tax Court · 1984
- Martin v. CommissionerUnited States Tax Court · 1985
- Estate of Meyer v. CommissionerUnited States Tax Court · 1985
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