Estate of Mapes v. Comm'r
United States Tax Court
Estate sought to elect the special use valuation of farm property under sec. 2032A, I.R.C., and further sought, in the event that the special use valuation were disapproved, to elect the alternate valuation method under sec. 2032, I.R.C.Held, estate failed to prove that its farm property satisfied the 50-percent test of sec. 2032A(b)(1)(A), I.R.C.Held, further, petitioner made a valid election of the alternate valuation method under sec. 2032.
1Opinion of the Court
Whalen, Judge:
Respondent determined a deficiency of $106,470.41 in petitioner’s Federal estate tax. We are called upon to decide two issues. The first is whether petitioner is entitled to elect the special use valuation of farm property provided by section 2032A. Unless stated otherwise, all section references are to the Internal Revenue Code in effect on the date of the decedent’s death. This issue turns on whether the decedent’s farm property satisfies the 50-percent test of section 2032A(b)(l)(A) for qualified real property. The second issue for decision is whether petitioner made a valid…
2Cases cited14 opinions
- Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
- Pacific National Co. v. WelchSupreme Court of the United States · 1938
- Downe v. CommissionerUnited States Tax Court · 1943
- Estate of Gunland v. CommissionerUnited States Tax Court · 1987
- Estate of Geiger v. CommissionerUnited States Tax Court · 1983
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3Cited by5 opinions
- LeFever v. CommissionerUnited States Tax Court · 1994
- Stovall v. CommissionerUnited States Tax Court · 1993
- Estate of Mapes v. Comm'rUnited States Tax Court · 1992
- LeFever v. CommissionerUnited States Tax Court · 1994
- Stovall v. CommissionerUnited States Tax Court · 1993