Estate of Loren Doherty, Deceased, Dan A. Doherty, Personal Representative v. Commissioner of Internal Revenue

McWILLIAMS, Senior Circuit Judge.

This case concerns a deficiency notice filed by the Commissioner of the Internal Revenue Service (IRS) in a federal estate tax proceeding. Dan A. Doherty, as personal representative of his deceased wife’s estate, filed a timely federal estate tax return. On that return, he made an election that certain ranch land belonging to his deceased wife be valued at its “special use value,” as opposed to its “fair market value.” 1 The Commissioner ruled that the personal representative’s special use valuation election was invalid and accordingly sent the estate a notice…