Timothy S. Heffley, as of the Estate of Opal P. Heffley, Deceased v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that special use valuation is unavailable when “the farmland was leased on a fixed-price basis to an outsider”
• noting Tax Court finding that “neither [the owner] nor a member of her family had materially participated in operating the farm”
• “Whether farm prices fluctuated or crops flourished or died their rental income would be unaffected because those heirs were rentiers throughout the lease, not farmers who risked the variables of weather and market price.”
• “While Congress will allow certain exceptional preferences to avoid excessive tax burdens under certain conditions, in order to achieve the congressional intent these exceptions must be narrowly applied and the corresponding exclusions broadly interpreted.”
• retired decedent and full-time student heir leased entire 280 acres

Source: CourtListener parenthetical corpus (CC0).