Estate of Abell v. Commissioner
United States Tax Court
D leased her ranch for a fixed sum to an unrelated third party who conducted cattle operations. D resided on the ranch until the time of her death and participated in the operation of the ranch. Held, D's ranch does not constitute "qualified real property" under sec. 2032A(b), I.R.C. 1954, because D had no equity or financial interest in the cattle business being conducted on her property.
1Opinion of the Court
Wiles, Judge:
Respondent determined a deficiency in decedent’s Federal estate tax in the amount of $225,818. After concessions, the sole issue for decision is whether the decedent’s ranch qualifies for a special use valuation under section 2032A.1
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Flora J. Abell (hereinafter decedent) died on January 4, 1979. Petitioners Juanita Abell Pyle (Juanita) and Harry A. Waite (Waite) are the coexecutors of decedent’s estate. Juanita resided in Ashland, KS, and Waite resided in Dodge City, KS, at the time the petition…
2Cases cited3 opinions
- Estate of Coon v. CommissionerUnited States Tax Court · 1983
- Estate of Sherrod v. CommissionerUnited States Tax Court · 1984
- Estate of Trueman v. United StatesUnited States Court of Claims · 1984
3Cited by27 opinions
- Estate of Gunland v. CommissionerUnited States Tax Court · 1987
- Merle Schuneman and Robert Doty, Trustees Under Trust Agreement Dated April 10, 1977, With Kathryn M. Keefe, as Settlor v. United StatesCourt of Appeals for the Seventh Circuit · 1986
- Beryl P. Williamson v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1992
- Estate of H. Floyd Sherrod, H. Floyd Sherrod, Jr. And Estalee Sherrod Sandlin, Co-Executors v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- McDonald v. CommissionerUnited States Tax Court · 1987
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