Richard D. Hohenstein - Page 3

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          contained a special use election pursuant to section 2032A                  
          requesting valuation of the decedent's real estate located in               
          Nicollet County, Minnesota (the Nicollet farm), based on the                
          qualified use of such property for farming.  The Nicollet farm              
          comprised approximately 342 acres of real property with a fair              
          market value (based on highest and best use) of $626,200 at the             
          time of decedent's death.  With the special use election under              
          section 2032A, the value of the Nicollet farm was set at                    
          $304,869, which amount was included in decedent's taxable estate.           
               Petitioner inherited the Nicollet farm from his father and             
          is the qualified heir for section 2032A purposes.  In accordance            
          with section 2032A(d)(2), petitioner executed a Special Use                 
          Election Agreement (the Agreement) consenting to personal                   
          liability for additional estate tax, or "recapture" tax, on the             
          Nicollet farm to the extent that the property was disposed of, or           
          ceased to be used for a qualified purpose, during the applicable            
          post-death period.  As required by section 20.2032A-8(c)(1),                
          Estate Tax Regs., the Agreement designated an agent, C. Thomas              
          Wilson, to represent the qualified heir of the estate.                      
               As filed, the estate tax return showed a total estate tax              
          due of $4,685.  Had the parties not elected the special use                 
          valuation for the farm, the estate would have owed an additional            
          $120,988 in estate taxes at the time the return was filed.                  
          However, the requirements of section 2032A were met, and the                






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