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ESTATE OF BRANDES v. COMMISSIONER

Docket No. 27513-84.

87 T.C. 592 (1986)

ESTATE OF ELMIRA S. BRANDES, DECEASED, ROBERT S. BRANDES, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 8, 1986.

Attorney(s) appearing for the Case

Emmanuel F. Guyon, for the petitioner.

Lauren W. Gore, for the respondent.

OPINION

SIMPSON, Judge:

The Commissioner determined a deficiency of $14,630.57 in the estate tax of the petitioner. The issues for decision are: (1) Whether an estate can value a farm under section 2032A of the Internal Revenue Code of 19541 with respect to which the decedent had entered into a contract of sale; and (2) whether section 2036 is applicable to such sale.

All of the facts have been stipulated, and...

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