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ESTATE OF THOMPSON v. COMMISSIONER

Docket No. 9879-86.

89 T.C. 619 (1987)

ESTATE OF JAMES U. THOMPSON, DECEASED, SUSAN T. TAYLOR, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 17, 1987.

Attorney(s) appearing for the Case

Michael E. Marr, for the petitioner.

Mary C. Gorman, for the respondent.

WILLIAMS, Judge:

The Commissioner determined a deficiency in petitioner's Federal estate tax in the amount of $509,957. After concessions by the parties, the issues this Court must decide are (1) whether petitioner may elect special use valuation for segments of two farms pursuant to section 2032A,1 and (2) the fair market value of four farm properties in the decedent's estate.

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