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ESTATE OF ROGERS v. COMMISSIONER

Docket No. 2796-97.

79 T.C.M. 1891 (2000)

T.C. Memo. 2000-133

Estate of Carolyn J. Rogers, Deceased, John A. Rogers III, Executor v. Commissioner.

United States Tax Court.

Filed April 12, 2000.

Attorney(s) appearing for the Case

David D. Aughtry and Howard W. Neiswender, Tuscaloosa, Alabama, for the petitioner. Robert W. West, for the respondent.

MEMORANDUM OPINION

HAMBLEN, Judge:

Respondent determined a deficiency of $305,997 in the Federal estate tax of the Estate of Carolyn J. Rogers (decedent). After concessions by the parties,1 the issue remaining for decision is the valuation of decedent's qualified and elected real property under section 2032A. There are two questions for determination:

(1) Whether petitioner can value the real property under the provisions...

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