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ESTATE OF GUNLAND v. COMMISSIONER

Docket No. 968-85.

88 T.C. 1453 (1987)

ESTATE OF CARL C. GUNLAND, DECEASED, R. ELAINE GUNLAND, EXECUTRIX, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 4, 1987.

Attorney(s) appearing for the Case

James H. Perkins and Walter S. Moeller, for the petitioner.

Steven Mather, for the respondent.

OPINION

COHEN, Judge:

Respondent determined a deficiency of $325,094 in petitioner's estate tax. After concessions, the issues for decision are: (1) Whether petitioner's failure to attach a recapture agreement of the type referred to in section 2032A(d)(2)1 to its original estate tax return defeats petitioner's attempted election of section 2032A special use valuation and, if not, (2) whether petitioner also may claim...

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