Estate of Strickland v. Commissioner
United States Tax Court
Decedent died on Jan. 3, 1982. Petitioner attempted to elect sec. 2032A, I.R.C. 1954, special use valuation on an amended Federal estate tax return timely filed on Oct. 4, 1982. In the notice of election, petitioner failed to supply the information and documentation necessary to substantiate the special value based on use pursuant to sec. 2032A(e)(7)(A) and sec. 20.2032A-4, Estate Tax Regs.
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Decedent died on Jan. 3, 1982. Petitioner attempted to elect sec. 2032A, I.R.C. 1954, special use valuation on an amended Federal estate tax return timely filed on Oct. 4, 1982. In the notice of election, petitioner failed to supply the information and documentation necessary to substantiate the special value based on use pursuant to sec. 2032A(e)(7)(A) and sec. 20.2032A-4, Estate Tax Regs. Held, petitioner has not "substantially complied" with the regulations under sec. 2032A(d)(3)(B).
1Opinion of the Court
GOFFE, Judge:
The Commissioner determined a deficiency in petitioner’s Federal estate tax in the amount of $34,814.42.
After concessions by petitioner, the sole issue remaining for decision is whether petitioner is entitled to value real property in the decedent’s estate at its special use value pursuant to section 2032A.1
FINDINGS OF FACT
Some of the facts of this case have been stipulated and are so found. The stipulation of facts and accompanying exhibits are incorporated by this reference.
Della Rose Schwartz, personal representative of the Estate of Pauline E. Strickland (the decedent), was a…
2Cases cited16 opinions
- Graves v. New York Ex Rel. O'KeefeSupreme Court of the United States · 1939
- Taylor v. CommissionerUnited States Tax Court · 1977
- Sperapani v. CommissionerUnited States Tax Court · 1964
- Estate of Ralph D. Cowser, Deceased, Patricia Ann Tucker v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1984
- Cary v. CommissionerUnited States Tax Court · 1963
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3Cited by18 opinions
- Estate of Doherty v. Comm'rUnited States Tax Court · 1990
- Estate of Malcolm McAlpine Jr., Deceased, Geraldine McAlpine Independent and Jocelyn McAlpine Greeman, Independent v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1992
- Elizabeth J. Bartlett, as of the Estate of Charles E. Grimes, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1991
- Estate of Harry M. Hudgins, Deceased, Lee C. Hudgins and Harry Hudgins Ii, Co-Independent Executors v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1995
- Estate of Merwin v. CommissionerUnited States Tax Court · 1990
13 more not listed; retrieve them via the Exa API.