MEMORANDUM OPINION
NIMS, Judge:
Respondent determined a deficiency of $93,866 in additional Federal estate tax against Richard D. Hohenstein (petitioner or Hohenstein), a qualified heir who received farm real estate subject to section 2032A. The sole issue for decision is whether petitioner ceased to use qualified real property for a qualified use, rendering him liable for additional estate tax pursuant to section 2032A(c)....
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