Martin v. Commissioner
United States Tax Court
P's are the seven heirs of the Estate of John A. Fischer. At his death on Jan. 29, 1978, decedent devised to such heirs, as tenants in common, a 209-acre crop-producing family farm. The farm was leased on a sharecrop basis to the son-in-law of decedent at the time of his death.
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P's are the seven heirs of the Estate of John A. Fischer. At his death on Jan. 29, 1978, decedent devised to such heirs, as tenants in common, a 209-acre crop-producing family farm. The farm was leased on a sharecrop basis to the son-in-law of decedent at the time of his death. The estate properly elected, qualified for, and received a special-use valuation pursuant to sec. 2032A, I.R.C. 1954. At the instigation of the personal representative, who was an heir, and over the opposition of two of the heirs, a 1-year cash lease of the entire tillable portion of the farm was executed in August of…
1Opinion of the Court
Korner, Judge:
Respondent determined deficiencies in estate tax against each of the foregoing seven petitioners in the amount of $95,088.14.1 Respondent has conceded $81,504.12 of each such deficiency, leaving deficiency determinations in the amount of $13,584.02 in issue as to each petitioner.2
After concessions, the sole issue remaining for our decision is whether the seven heirs of the decedent, John A. Fischer, ceased to use qualified real property for a qualified use, so that they are liable for an additional estate tax pursuant to section 2032A(c).3
FINDINGS OF FACT
Some of the facts have…
2Cases cited6 opinions
- Jarecki v. G. D. Searle & Co.Supreme Court of the United States · 1961
- Estate of Coon v. CommissionerUnited States Tax Court · 1983
- Estate of Abell v. CommissionerUnited States Tax Court · 1984
- Estate of Sherrod v. CommissionerUnited States Tax Court · 1984
- Estate of Trueman v. United StatesUnited States Court of Claims · 1984
1 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Estate of Wallace v. CommissionerUnited States Tax Court · 1990
- LeFever v. CommissionerCourt of Appeals for the Tenth Circuit · 1996
- Mary Jean Martin, and John R. Fischer v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- LeFever v. CommissionerUnited States Tax Court · 1994
- Estate of Maddox v. CommissionerUnited States Tax Court · 1989
17 more not listed; retrieve them via the Exa API.