Robert Whalen, of the Estate of Katherine B. Whalen, Deceased v. United States
Court of Appeals for the Seventh Circuit
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…
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