MOYE, Chief District Judge:
The government appeals from a decision of the tax court, 82 T.C. 523, holding that certain property of the estate of H. Floyd Sherrod (the estate) qualified for special use valuation for federal estate tax purposes under 26 U.S.C. § 2032A of the Internal Revenue Code of 1954. We reverse.
I.
Tax Court Proceedings
The relevant facts, as reflected in the tax court's findings, the parties' stipulations...
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