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WILLIAMSON v. C.I.R.

No. 89-70506.

974 F.2d 1525 (1992)

Beryl P. WILLIAMSON, Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided September 14, 1992.

Attorney(s) appearing for the Case

Robert K. Smith, Shannahan, Smith & Dailey, La Jolla, Cal., for petitioner-appellant.

Bruce R. Ellisen, Tax Div., U.S. Dept. of Justice, Washington, D.C., for respondent-appellee.

Before: TANG, REINHARDT, and WIGGINS, Circuit Judges.

TANG, Circuit Judge:

Beryl Williamson inherited farm land from his mother in 1983. In the estate tax return, Williamson elected the special use valuation for the property provided by 26 U.S.C. § 2032A. Williamson subsequently leased the farm to his nephew for a fixed, semi-annual cash payment. In 1987, the Internal Revenue Service ("IRS") issued a Notice of Deficiency to Williamson, asserting that the cash lease rendered...

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