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ESTATE OF HOOVER v. C.I.R.

No. 94-9018.

69 F.3d 1044 (1995)

ESTATE OF Clara K. HOOVER, deceased; Yetta Hoover Bidegain, personal representative, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

November 1, 1995.

Attorney(s) appearing for the Case

John S. Campbell of Campbell & Wells, P.A., Albuquerque, New Mexico, for Petitioner-Appellant.

Robert W. Meltzer, Attorney, Tax Division, Department of Justice, Washington, DC, for Respondent-Appellee.

Before KELLY, McWILLIAMS and HENRY, Circuit Judges.

PAUL KELLY, Jr., Circuit Judge.

Petitioner appeals from the tax court's imposition of additional federal estate taxes on the estate of Clara K. Hoover, arising from an election to value the decedent's minority interest in certain ranch property under I.R.C. § 2032A at its special use value rather than at fair market value. The estate contends that § 2032A allows it to apply a minority interest discount to arrive at the fair market value of the decedent's...

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