United States Tax Court June 4, 1987, Docket No. 968-85 (Estate of Gunland v. Commissioner)

lead-opinion

OPINION

COHEN, Judge:

Respondent determined a deficiency of $325,094 in petitioner’s estate tax. After concessions, the issues for decision are: (1) Whether petitioner’s failure to attach a recapture agreement of the type referred to in section 2032A(d)(2)1 to its original estate tax return defeats petitioner’s attempted election of section 2032A special use valuation and, if not,