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ESTATE OF SHERROD v. COMMISSIONER

Docket No. 5531-82.

082 T.C. 523 (1984)

ESTATE OF H. FLOYD SHERROD, H. FLOYD SHERROD, JR., AND ESTALEE SHERROD SANDLIN, COEXECUTORS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 26, 1984.

Attorney(s) appearing for the Case

J. Gilmer Blackburn and Mark Daniel Maloney, for the petitioner.

Linda J. Wise, for the respondent.

SHIELDS, Judge:

Respondent determined a deficiency of $170,693.08 in the Federal estate tax due from the Estate of H. Floyd Sherrod. After concessions, the issues remaining for decision are: (1) Does the estate qualify for special use valuation under section 2032A1 for certain land; (2) does the Tax Court have jurisdiction to review respondent's determination that the estate does not qualify to pay the estate tax in installments...

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