Williamson v. Commissioner
United States Tax Court
Decedent devised farm property to petitioner, her son, and her estate properly elected to value the property under the special use valuation provisions of sec. 2032A, I.R.C. 1954. After decedent's death, petitioner leased the property to his nephew for a cash rental. Held, the lease of the property to petitioner's nephew caused a cessation of the qualified use of the property and petitioner is liable for the additional estate tax imposed by sec. 2032A(c)(1), I.R.C. 1954.
1Opinion of the Court
OPINION
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $42,026 in estate tax against petitioner Beryl P. Williamson under section 2032A(c)(l).1 The deficiency was determined against petitioner in his capacity as qualified heir of Elizabeth R. Williamson (hereinafter decedent), his mother, who died on July 27, 1983.
The issue for decision is whether petitioner is Hable for the additional estate tax imposed by section 2032A(c)(l) because a cessation of quahfied use occurred when petitioner cash leased to his nephew farm property which decedent devised to him and with…
2Cases cited18 opinions
- Red Lion Broadcasting Co. v. Federal Communications CommissionSupreme Court of the United States · 1969
- Commissioner v. Gillette Motor Transport, Inc.Supreme Court of the United States · 1960
- Hellmich v. HellmanSupreme Court of the United States · 1928
- In the Matter of Gerald Lewis Tarnow, Debtor. Appeal of Commodity Credit CorporationCourt of Appeals for the Seventh Circuit · 1984
- Lewyt Corp. v. CommissionerSupreme Court of the United States · 1955
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3Cited by13 opinions
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- Fisher v. CommissionerUnited States Tax Court · 1993
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