Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined a deficiency of $194,294 in decedent's Federal estate tax. The issue for decision is the special use valuation of 41.37 acres of agricultural real property in Ventura County, California, on the date of decedent's death.
All section references are to the Internal Revenue Code of 1954 as amended and in effect on the date of decedent's death. All Rule references are to the Tax...
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