ESTATE OF COWSER v. C.I.R.

No. 83-2329.

736 F.2d 1168 (1984)

ESTATE OF Ralph D. COWSER, Deceased, Patricia Ann Tucker, Executor, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided June 13, 1984.


Attorney(s) appearing for the Case

Gery R. Gasick, McConnell, Kennedy, Quinn & Johnston, Peoria, Ill., for petitioner-appellant.

Thomas A. Gick, Atty., Tax Div., Dept. of Justice, Washington, D.C., for respondent-appellee.

Before BAUER, WOOD and COFFEY, Circuit Judges.


HARLINGTON WOOD, Jr., Circuit Judge.

Ralph D. Cowser died on March 15, 1978, leaving no surviving descendants. He devised his family farm to his deceased wife's grandniece and her husband, Patricia and Hartley Tucker. Patricia Tucker, as executrix of Ralph Cowser's estate, attempted to invoke the special use valuation provisions of section 2032A of the Internal Revenue Code, 26 U.S.C. § 2032A (1976). The Internal Revenue Service found that the grandniece was...

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