HOHENSTEIN v. COMMISSIONER

Docket No. 22282-94.

73 T.C.M. 1886 (1997)

T.C. Memo. 1997-56

Richard D. Hohenstein v. Commissioner.

United States Tax Court.

Filed January 30, 1997.


Attorney(s) appearing for the Case

C. Thomas Wilson, New Ulm, Minn., for the petitioner. Mary E. Dean and John C. Schmittdiel, for the respondent.


MEMORANDUM OPINION

NIMS, Judge:*

Respondent determined a deficiency of $93,866 in additional Federal estate tax against Richard D. Hohenstein (petitioner or Hohenstein), a qualified heir who received farm real estate subject to section 2032A. The sole issue for decision is whether petitioner ceased to use qualified real property for a qualified use, rendering him liable for additional estate tax pursuant to section 2032A(c)....

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