Legal Opinion
Timothy S. Heffley, as of the Estate of Opal P. Heffley, Deceased v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided August 17, 1989No. 88-1929PublishedCited by 16 opinions
1Opinion of the Court
MANION, Circuit Judge.
Opal P. Heffley died in 1981. Her estate claimed the right to value under the special use valuation provisions of 26 U.S.C. § 2032A a farm in which Opal had held an interest. The Commissioner of Internal Revenue disagreed, and assessed a federal estate tax deficiency. The Tax Court determined that the property had not been put to a statutorily qualified use. We affirm.
I
FACTS
History of the farm
Opal P. Heffley died on September 23, 1981 at age 67. Her son Timothy Heffley is the duly appointed, qualified and acting executor of her estate.
Opal Heffley’s estate included a…
2Cases cited11 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- Estate of Ralph D. Cowser, Deceased, Patricia Ann Tucker v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1984
- Estate of Baumgardner v. CommissionerUnited States Tax Court · 1985
- Eli Lilly & Company and Subsidiaries, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1988
6 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- First National Bank v. Woods (In Re Woods)Court of Appeals for the Tenth Circuit · 2014
- U.S. Freightways Corp., F.K.A. Tnt Freightways Corp., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2001
- Beryl P. Williamson v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1992
- Lawinger v. Comm'rUnited States Tax Court · 1994
- LeFever v. CommissionerUnited States Tax Court · 1994
11 more not listed; retrieve them via the Exa API.