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decedent must have been a citizen or resident of the United
States, and the subject property must be located in the United
States; (2) at least 50 percent of the adjusted value of the
gross estate must consist of the adjusted value of real or
personal property which, on the date of decedent's death, was
being used for a qualified use by the decedent or a member of his
family, and was acquired from or passed from the decedent to a
qualified heir; (3) a minimum of 25 percent of the adjusted value
of the gross estate must consist of the adjusted value of real
property that passes to a qualified heir and that at least 5
years in the 8-year period immediately preceding decedent's death
was owned by decedent or a member of his family and used for a
qualified use; and (4) the decedent or a member of his family
must materially participate in the operation of the farm or
business. Secs. 2032A(a)(1) and (b)(1).
The above requirements all show 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). Moreover, the benefit
afforded by section 2032A is not open-ended; the maximum
aggregate reduction in value allowable by the statute for
qualified real property with respect to any decedent is $750,000.
Sec. 2032A(a)(2).
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