Shaw v. Commissioner
United States Tax Court
P, a qualified heir, received ranch property subject to a special use valuation election pursuant to I.R.C. sec. 2032A. P leased the ranchland to her son for $ 2 per acre. Held, P ceased to use the property for its qualified use and is liable for additional Federal estate tax imposed by I.R.C. sec. 2032A(c). Williamson v. Commissioner, 93 T.C. 242 (1989), followed. Held further, P is liable for the addition to tax imposed by I.R.C. sec. 6651(a)(1).
1Opinion of the Court
LAVONA PAULINE SHAW, QUALIFIED HEIR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Shaw v. Commissioner
Docket No. 5219-89
United States Tax Court
T.C. Memo 1991-372; 1991 Tax Ct. Memo LEXIS 424; 62 T.C.M. (CCH) 396; T.C.M. (RIA) 91372;
August 8, 1991, Filed
Decision will be entered under Rule 155.
P, a qualified heir, received ranch property subject to a special use valuation election pursuant to I.R.C. sec. 2032A. P leased the ranchland to her son for $ 2 per acre. Held, P ceased to use the property for its qualified use and is liable for additional Federal estate tax imposed by…
2Cases cited6 opinions
- United States v. BoyleSupreme Court of the United States · 1985
- Estate of Coon v. CommissionerUnited States Tax Court · 1983
- Mary Jean Martin, and John R. Fischer v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- Martin v. CommissionerUnited States Tax Court · 1985
- Estate of Strickland v. CommissionerUnited States Tax Court · 1989
1 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Fisher v. CommissionerUnited States Tax Court · 1993