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taxes. Estate of Mapes v. Commissioner, 99 T.C. 511, 516-517
(1992); H. Rept. 94-1380, supra, 1976-3 C.B. (Vol. 3) at 755-756;
S. Rept. 94-938 (Part 2), supra, 1976-3 C.B. (Vol. 3) at 657.
Although section 2032A is a relief statute designed to
encourage the continuation of family farms, it provides for
"exceptionally favorable tax treatment", and taxpayers must "come
within its demanding terms". Martin v. Commissioner, 783 F.2d
81, 82, 84 (7th Cir. 1986), affg. 84 T.C. 620 (1985). The succor
provided by section 2032A is limited in several ways: (1) The
decedent must have been a citizen or resident of the United
States, and the subject property must be located in the United
States; (2) the real property must have been used as a farm or in
a trade or business by the decedent or a member of the decedent's
family; (3) the decedent or a member of his family must
materially participate in the operation of the farm or the
business; and (4) real property qualifies for special use
valuation only if it passes to a member of the decedent's family.
Sec. 2032A(c). These requirements all evidence Congress' intent
to limit the tax relief to what is generally regarded as a family
farm or business. See Estate of Heffley v. Commissioner, 89 T.C.
265, 271 (1987), affd. 884 F.2d 279 (7th Cir. 1989); Estate of
Geiger v. Commissioner, 80 T.C. 484, 488 (1983).
In enacting the special use valuation provisions, Congress
also recognized that an estate's beneficiaries would enjoy an
unwarranted windfall if they should sell the property within a
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