Legal Opinion

Robert Whalen, of the Estate of Katherine B. Whalen, Deceased v. United States

Court of Appeals for the Seventh Circuit

Decided August 13, 1987No. 86-2997PublishedCited by 16 opinions

1Opinion of the Court

WILL, Senior District Judge.

Katherine B. Whalen died on April 14, 1977. In her will, Whalen devised nearly one hundred acres of Illinois farm land to her three sons and stepdaughter, Catherine Brown. Whalen’s estate claimed special use valuation under § 2032A of the Internal Revenue Code, 26 U.S.C. § 2032A, for all of the farmland. The Internal Revenue Service denied special use valuation for the quarter interest devised to Catherine Brown, finding that a stepchild was not a “qualified heir” as required by § 2032A. A magistrate and the district court agreed with the IRS determination.

On…

2Cases cited4 opinions

  1. Red Lion Broadcasting Co. v. Federal Communications CommissionSupreme Court of the United States · 1969
  2. National Fidelity Life Insurance Co. v. Joan KaraganisCourt of Appeals for the Seventh Circuit · 1987
  3. Estate of Ralph D. Cowser, Deceased, Patricia Ann Tucker v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1984
  4. Estate of Abell v. CommissionerUnited States Tax Court · 1984

3Cited by16 opinions

  1. LeFever v. CommissionerCourt of Appeals for the Tenth Circuit · 1996
  2. Estate of James U. Thompson, Deceased Susan T. Taylor, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1989
  3. Confederated Tribes of Coos, Lower Umpqua & Siuslaw Indians v. BabbittDistrict Court, District of Columbia · 2000
  4. In Re Consolidated Litigation Concerning International Harvester's Disposition of Wisconsin SteelDistrict Court, N.D. Illinois · 1988
  5. Elizabeth J. Bartlett, as of the Estate of Charles E. Grimes, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1991

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