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ESTATE OF HEFFLEY v. COMISSIONER

Docket No. 3201-85.

89 T.C. 265 (1987)

ESTATE OF OPAL P. HEFFLEY, DECEASED, TIMOTHY S. HEFFLEY, EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 11, 1987.

Attorney(s) appearing for the Case

Stephen J. Williams, for the petitioner.

Russell D. Pinkerton, for the respondent.

SIMPSON, Judge:

The Commissioner determined a deficiency of $84,373.47 in the petitioner's Federal estate tax. After concessions, the issues for our decision are: (1) Whether the petitioner is entitled to value real property in which the decedent held an interest at her death by use of the special use valuation provisions of section 2032A, Internal Revenue Code of 1954;1 and (2) whether...

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