United States Tax Court August 11, 1987, Docket No. 3201-85 (Estate of Heffley v. Commissioner)

lead-opinion

SIMPSON, Judge:

The Commissioner determined a deficiency of $84,373.47 in the petitioner’s Federal estate tax. After concessions, the issues for our decision Eire: (1) Whether the petitioner is entitled to value real property in which the decedent held an interest at her death by use of the special use valuation provisions of section 2032A, Internal Revenue Code of 1954;1 and (2)