MAGILL, Circuit Judge.
The Estate of Verdon Gavin (the Gavin estate) brought this tax refund suit against the government, alleging that the Gavin estate is entitled to (1) value certain farmland under the special use valuation provisions of Internal Revenue Code (I.R.C.) § 2032A (1988 & Supp. II 1990) and (2) use a stepped-up basis under I.R.C. § 1014 (1988 & Supp. II 1990) to calculate taxable income from the sale of grain and livestock. The district...
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