Court of Appeals for the Eighth Circuit May 8, 1997, 96-3462 (Estate of Verdon Gavin v. United States)

MAGILL, Circuit Judge.

The Estate of Verdón Gavin (the Gavin estate) brought this tax refund suit against the government, alleging that the Gavin estate is entitled to (1) value certain farmland under the special use valuation provisions of Internal Revenue Code (I.R.C.) § 2032A (1988 & Supp. II 1990) and (2) use a stepped-up basis under I.R.C. § 1014 (1988 & Supp.