ESTATE OF WOOD v. COMMISSIONER

Docket No. 48020-86.

92 T.C. 793 (1989)

ESTATE OF LEONARD A. WOOD, DECEASED, J.M. LOONAN, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 12, 1989.


Attorney(s) appearing for the Case

Michael D. Johnson, for the petitioner.

Gail K. Gibson, for the respondent.


WILLIAMS, Judge:

The Commissioner determined a deficiency in petitioner's 1981 Federal estate tax of $38,636.54. The issue we must decide is whether petitioner timely elected special use valuation pursuant to section 2032A(d).1

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. Decedent Leonard A. Wood, a Minnesota resident, died on June 21, 1981, owning farmland valued pursuant to section...

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