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LeFEVER v. C.I.R.

No. 95-9022.

100 F.3d 778 (1996)

William LeFEVER, Qualified Heir-Transferee of the Assets of the Estate of Blanche Knollenberg, Betty Lou LeFever, Qualified Heir-Transferee of the Assets of the Estate of Blanche Knollenberg, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Tenth Circuit.

November 13, 1996.

Attorney(s) appearing for the Case

Patrick J. Regan of Regan & McGannon, Wichita, KS, and Juandell D. Glass, Norman, OK, for Petitioners-Appellants.

Gilbert S. Rothenberg and Andrea R. Tebbets, Attorneys, Tax Division, Department of Justice, Washington, DC, for Respondent-Appellee.

Before BALDOCK, McWILLIAMS, and RONEY, Circuit Judges.

BALDOCK, Circuit Judge.

In a federal estate tax return, Petitioners valued several parcels of inherited farmland under the special use valuation election, 26 U.S.C. § 2032A, which reduced the valuation of the land from its fair market value. Seven years after they filed the election, Respondent determined that they were not putting the land to a qualifying use as required to maintain the benefits of the election, and assessed additional taxes against Petitioners...

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