WHALEN, Judge:
Respondent determined a deficiency of $106,470.41 in petitioner's Federal estate tax. We are called upon to decide two issues. The first is whether petitioner is entitled to elect the special use valuation of farm property provided by section 2032A. Unless stated otherwise, all section references are to the Internal Revenue Code in effect on the date of the decedent's death. This issue turns on whether the decedent's farm property satisfies the...
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