Estate of Klosterman v. Commissioner
United States Tax Court
At the time of his death, D owned farmland in Idaho. The farmland is situated in two irrigation districts, which are political subdivisions of the State of Idaho. The parties agree that the farmland is to be valued pursuant to sec. 2032A(e)(7)(A), I.R.C.
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At the time of his death, D owned farmland in Idaho. The farmland is situated in two irrigation districts, which are political subdivisions of the State of Idaho. The parties agree that the farmland is to be valued pursuant to sec. 2032A(e)(7)(A), I.R.C. Pursuant to sec. 2032A(e)(7)(A), the value of farmland is established by computing the "average annual gross cash rental" for comparable farmland in the area for the 5-year period preceding the decedent's death, subtracting from such average rentals the average State and local real estate taxes for the same period, and dividing the result by…
1Opinion of the Court
OPINION
Raum, Judge:
The Commissioner determined a deficiency in petitioner’s estate tax in the amount of $18,015. At the time the petition in this case was filed, petitioner’s personal representatives resided in the State of Idaho. The case was submitted on the basis of a stipulation of facts and exhibits pursuant to our Rule 122.1 As a result of concessions by petitioner, the main issue remaining for our decision involves the valuation, pursuant to section 2032A(e)(7)(A), of certain farmland owned by Walter F. Klosterman (decedent) at the time of his death. In addition, petitioner has asked…
2Cases cited3 opinions
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Noon v. Gem Irr. Dist.District Court, D. Idaho · 1913
- Noble v. CommissionerUnited States Tax Court · 1978
3Cited by2 opinions
- Estate of Klosterman v. CommissionerUnited States Tax Court · 1992
- Estate of Walter F. Klosterman, Deceased Kent Klosterman Alan Klosterman, Personal Representatives v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1994