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McCOY v. COMMISSIONER

Docket No. 19540-83.

50 T.C.M. 1194 (1985)

T.C. Memo. 1985-509

Estate of Arthur H. McCoy, Deceased, Robert McCoy, Executor v. Commissioner.

United States Tax Court.

Filed September 26, 1985.

Attorney(s) appearing for the Case

Walter E. Schutt, for the petitioner. Nancy B. Herbert, for the respondent.

Memorandum Opinion

FEATHERSTON,1 Judge:

Respondent determined a deficiency in petitioner's estate tax in the amount of $22,159.72. The issue for decision is whether petitioner effectively elected to have the interest of the decedent, Arthur H. McCoy, in certain real property valued under section 2032A2 as special use property rather than at its full fair market value.

All the facts are stipulated...

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