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ESTATE OF JOHNSON v. COMMISSIONER

Docket No. 37085-85.

89 T.C. 127 (1987)

ESTATE OF CURTIS H. JOHNSON, DECEASED, KIRBY JOHNSON, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 20, 1987.

Attorney(s) appearing for the Case

Robert S. Mucklestone, for the petitioner.

Larry N. Johnson, for the respondent.

OPINION

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $123,735 in petitioner's estate tax and an addition to tax under section 6651(a)1 in the amount of $6,187. The issues for decision are:

(1) Whether petitioner effectively elected to have decedent's interest in certain parcels of real property valued under section 2032A as special use property rather than at its full fair market value...

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