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ESTATE OF WARD v. COMMISSIONER

Docket No. 20600-80.

89 T.C. 54 (1987)

ESTATE OF REBECCA WARD, DECEASED, FLORAL EMERSON AND REBA HARRIS, COTRUSTEES AND COEXECUTRICES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 8, 1987.

Attorney(s) appearing for the Case

Clarence E. Price and Karen L. Krodel, for the petitioner.

Elsie Hall and Russell D. Pinkerton, for the respondent.

CHABOT, Judge:

Respondent determined a deficiency in Federal estate tax against petitioner in the amount of $46,331.82. After a concession by petitioner, the issue for decision is whether decedent materially participated in the operation of her farm within the meaning of section 2032A(b)(1)(C)(ii)1 so as to permit her estate to qualify for the benefits of the special use valuation provisions of section 2032A.

FINDINGS OF...

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