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ESTATE OF SEQUEIRA v. COMMISSIONER

Docket No. 16264-91.

70 T.C.M. 761 (1995)

T.C. Memo. 1995-450

Estate of Joseph A. Sequeira, Deceased, George Sequeira and Albert Sequeira, Executors v. Commissioner.

United States Tax Court.

Filed September 21, 1995.

Attorney(s) appearing for the Case

John A. McNamara, for the petitioner. Debra Bowe, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

WRIGHT, Judge:

Respondent determined that there is a deficiency in petitioner's Federal estate tax in the amount of $297,461. The sole issue for our decision is whether petitioner made a valid election for special use valuation under section 2032A.1

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly. The stipulation of facts and the attached...

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