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ESTATE OF PULLIN v. COMMISSIONER

Docket No. 18606-82.

84 T.C. 789 (1985)

ESTATE OF MARVIN F. PULLIN, DECEASED, BENHAM M. BLACK, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 1, 1985.

Attorney(s) appearing for the Case

Benham M. Black, for the petitioner.

T. Keith Fogg and Scott Anderson, for the respondent.

OPINION

GOFFE, Judge:

The Commissioner determined a deficiency in petitioner's Federal estate tax in the amount of $9,303.25. The sole issue for our decision1 is whether the written agreement filed by an estate, in electing the special valuation of farm property as required by section 2032A(a)(1)(B)2 and section 2032A(d)(2), must be executed not only by the beneficiaries of the decedent's estate...

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