LeFever v. Commissioner
United States Tax Court
Ps as heirs of D received parcels of farmland from D's estate. For estate tax purposes, D's estate elected to specially value the farmland under sec. 2032A(a), I.R.C. As a condition precedent to the election, sec. 2032A(a), I.R.C., requires all persons having an interest in the property subject to the election to enter into an agreement described in sec. 2032A(d), I.R.C. Ps executed the written agreements described in sec. 2032A(d), I.R.C.
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Ps as heirs of D received parcels of farmland from D's estate. For estate tax purposes, D's estate elected to specially value the farmland under sec. 2032A(a), I.R.C. As a condition precedent to the election, sec. 2032A(a), I.R.C., requires all persons having an interest in the property subject to the election to enter into an agreement described in sec. 2032A(d), I.R.C. Ps executed the written agreements described in sec. 2032A(d), I.R.C. In the agreements, Ps (1) asserted that the land was qualified real property and that they were qualified heirs of D, (2) consented to the election to…
1Opinion of the Court
Parker, Judge:
Respondent determined a deficiency in additional Federal estate tax under section 2032A(c) in the amount of $38,154.33 and an addition to tax under section 6651(a)(1) in the amount of $9,538.58 against petitioner William LeFever. Respondent determined a deficiency in additional Federal estate tax under section 2032A(c) in the amount of $91,850.95 and an addition to tax under section 6651(a)(1) in the amount of $22,962.74 against petitioner Betty Lou LeFever.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years before the…
2Cases cited29 opinions
- Burnet v. Commonwealth Improvement Co.Supreme Court of the United States · 1932
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Danielson v. CommissionerUnited States Tax Court · 1965
- Ullman v. CommissionerCourt of Appeals for the Second Circuit · 1959
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
24 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Cluck v. CommissionerUnited States Tax Court · 1995
- Estate of Letts v. CommissionerUnited States Tax Court · 1997
- Zapara v. Comm'rUnited States Tax Court · 2006
- Parekh v. CommissionerUnited States Tax Court · 1998
- Estate of Posner v. Comm'rUnited States Tax Court · 2004
23 more not listed; retrieve them via the Exa API.