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ESTATE OF GRIMES v. COMMISSIONER

Docket No. 33429-84.

56 T.C.M. 890 (1988)

T.C. Memo. 1988-576

Estate of Charles E. Grimes, Deceased, Elizabeth J. Bartlett, Executrix v. Commissioner.

United States Tax Court.

Filed December 20, 1988.

Attorney(s) appearing for the Case

Merrick C. Hayes, for the petitioner. Michael W. Bitner, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined a deficiency of $346,157.94 in the Federal estate tax of the Estate of Charles E. Grimes, who died in 1980. After concessions, the issues for decision are:

(1) Whether the estate made a valid election for special use valuation under section 2032A1 where "the recapture agreement" was prepared and executed...

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