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MANGELS v. U.S.

No. 86-1647.

828 F.2d 1324 (1987)

Ruben W. MANGELS, Administrator of the Estate of Luella R. Mangels, deceased, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided September 16, 1987.

Attorney(s) appearing for the Case

Thomas C. Fritzsche, Bettendorf, Iowa, for appellant.

Michael C. Durney, of the Dept. of Justice, Washington, D.C., for appellee.

Before ARNOLD and WOLLMAN, Circuit Judges, and BOGUE, Senior District Judge.

WOLLMAN, Circuit Judge.

Ruben W. Mangels, administrator of the estate of Luella R. Mangels (the estate), appeals from a district court judgment that denied a refund for overpayment of federal estate tax based on special use valuation of farmland under section 2032A of the Internal Revenue Code, 632 F.Supp. 1555. The district court held that the acts of the court-appointed conservator did not fulfill the material participation...

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