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Messrs. Lanier and Pearce consulted 10 experts concerning
the most prudent method for selling Fishbranch and the ranch
assets. All the experts advised that cattle should continue to
graze on the land until it was sold. If not maintained by cattle
grazing, land in the part of Florida in which the Basinger and
Fishbranch tracts are located quickly reverts to its native state
and deteriorates into overgrown muck and swamp, decreasing its
value and making it more difficult to sell.
On the Federal estate tax return, timely filed on
February 17, 1992, petitioner listed $257,654 as expenses
relating to the operation of the cattle ranch, and deducted that
amount as expenses of administration of the estate. Petitioner
also noted on the return that additional cattle ranch expenses
would be deducted as incurred, on supplemental filings of the
Federal estate tax return.
Petitioner elected to pay Federal estate tax in
installments, as provided by section 6166. Under the election,
the first payment was due on February 17, 1997, 5 years after
February 17, 1992, the date the estate tax return was due.
On February 3, 1995, respondent issued a notice of
deficiency to petitioner. Petitioner’s petition, timely filed on
May 1, 1995, alleges, among other things, that expenses relating
to the operation of the cattle ranch are administration expenses
properly deductible from the gross estate in determining
petitioner's estate tax liability. Petitioner’s Second Amended
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