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ESTATE OF DAVIS v. COMMISSIONER

Docket No. 2383-82.

86 T.C. 1156 (1986)

ESTATE OF DAVID DAVIS IV, DECEASED, DAVID DAVIS V, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 11, 1986.

Attorney(s) appearing for the Case

Robert M. Bellatti and David J. Duez, for the petitioner.

Matthew J. Fritz, for the respondent.

SHIELDS, Judge:

Respondent determined a deficiency in petitioner's Federal estate tax in the amount of $1,332,388.48. The issues for decision are: (1) Whether petitioner is entitled to use the special use valuation for certain farm properties under section 2032A;1 and (2) whether the testamentary trust created by decedent for his surviving wife qualifies for the marital deduction under section 2056(b)(5).

FINDINGS OF FACT...

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