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WHALEN v. U.S.

No. 86-2997.

826 F.2d 668 (1987)

Robert WHALEN, Executor of the Estate of Katherine B. Whalen, Deceased, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided August 13, 1987.

Attorney(s) appearing for the Case

William L. Hatch, Hatch, Blockman, McPheters & Feherenbacher, Champaign, Ill., for plaintiff-appellant.

Janet Kay Jones, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.

Before POSNER and FLAUM, Circuit Judges, and WILL, Senior District Judge.

WILL, Senior District Judge.

Katherine B. Whalen died on April 14, 1977. In her will, Whalen devised nearly one hundred acres of Illinois farm land to her three sons and stepdaughter, Catherine Brown. Whalen's estate claimed special use valuation under § 2032A of the Internal Revenue Code, 26 U.S.C. § 2032A, for all of the farmland. The Internal Revenue Service denied special use valuation for the quarter interest...

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