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IN RE ESTATE OF LUCAS

No. 95-2370.

97 F.3d 1401 (1996)

In re ESTATE OF Charles R. LUCAS, Deceased, Plaintiff. Roy H. LUCAS; Howard C. Lucas, Co-Personal Representatives of the Estate of Charles R. Lucas, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

October 23, 1996.

Attorney(s) appearing for the Case

James David Pobjecky, Winter Haven, FL, for Plaintiffs-Appellants.

Gary R. Allen, Alice L. Ronk, Pat Bowman, Mark E. Matthews, Richard Farber, Tax Division, Dept. of Justice, Washington, D.C., for Defendant-Appellee.

Before HATCHETT, Circuit Judge, ANDERSON, Circuit Judge, and WOOD, Senior Circuit Judge.

ANDERSON, Circuit Judge:

In this federal estate tax case, the government determined that the Estate of Charles R. Lucas (the Estate) was not entitled to "special use valuation" of certain family farm property pursuant to section 2032A of the Internal Revenue Code. See 26 U.S.C. § 2032A. The first issue on appeal is whether the Estate's initial effort to elect special use valuation was sufficient to constitute "substantial compliance" with the applicable...

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