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ESTATE OF COFFING v. COMMISSIONER

Docket No. 20452-81.

53 T.C.M. 1314 (1987)

T.C. Memo. 1987-336

Estate of Elizabeth Coffing, Deceased, Thomas H. Coffing, Executor v. Commissioner.

United States Tax Court.

Filed July 8, 1987.

Attorney(s) appearing for the Case

Lester M. Ponder and Douglas P. Long, 11 So. Meridian St., Indianapolis, Ind., for the petitioner. Elsie Hall and Russell D. Pinkerton, for the respondent.

Memorandum Findings of Fact and Opinion

CHABOT, Judge:

Respondent determined a deficiency in Federal estate tax against petitioner in the amount of $62,505.59. After concessions, the issue for decision is whether decedent materially participated in the operation of her farms within the meaning of section 2032A(b)(1)(C)(ii),1 so as to permit petitioner to qualify for the benefits of special use valuation under section 2032A.<...

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