OPINION
NIMS, Chief Judge:
Respondent determined a deficiency of $111,228 in petitioner's Federal estate tax. The issue for decision is whether petitioner is entitled to value real property at its special use value pursuant to section 2032A. (Unless otherwise indicated, section references are to the Internal Revenue Code as amended and in effect at the date of decedent's death. Rule references are to the Tax Court Rules of Practice and Procedure....
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