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ESTATE OF THOMPSON v. C.I.R.

No. 88-3981.

864 F.2d 1128 (1989)

ESTATE OF James U. THOMPSON, Deceased; Susan T. Taylor, Personal Representative, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fourth Circuit.

Decided January 3, 1989.

Attorney(s) appearing for the Case

Donald Hayden Kelley (Kelley, Scritsmier, Moore & Byrne, P.C., North Platte, Neb., on brief), for petitioners-appellants.

David English Carmack, Washington, D.C. (William S. Rose, Jr., Charlotte, N.C., Gary R. Allen, John J. Boyle, Tax Div., Dept. of Justice, Washington, D.C., on brief), for respondent-appellee.

Before HALL, PHILLIPS, and WILKINSON, Circuit Judges.

K.K. HALL, Circuit Judge.

The estate of James U. Thompson ("decedent"), by its personal representative, Susan T. Taylor, daughter of the decedent, appeals the United States Tax Court's decision holding family farming property ineligible for the special use valuation provided by section 2032A of the Internal Revenue Code of 1954, 26 U.S.C. § 2032A. The Tax Court sustained the Internal Revenue Service's ("IRS") determination of a deficiency in federal estate taxes...

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