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ESTATE OF DOHERTY v. COMMISSIONER

Docket No. 5568-88.

95 T.C. 446 (1990)

ESTATE OF LOREN DOHERTY, DECEASED, DAN A. DOHERTY, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 18, 1990.

Attorney(s) appearing for the Case

Paul A. Kastler, for the petitioner.

Robert A. Varra, for the respondent.

OPINION

NIMS, Chief Judge:

Respondent determined a deficiency of $205,884 in petitioner's Federal estate tax. After concessions, the issues for decision are: (1) Whether petitioner is entitled to value real property at its special use value pursuant to section 2032A, even though petitioner did not attach a formal written appraisal to the filed estate tax return; and (2) for purposes of the marital deduction...

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