Estate of Lewis S. Thompson, III, Deceased, Synovus Trust Company, Successor Executor To Security Bank and Trust Company - Page 15

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          preceding the year of the decedent's death.  Sec. 20.2032A-                 
          4(b)(2)(i) and (iv), Estate Tax Regs.                                       
               The determination of whether property is comparable is a               
          factual one and is made according to "generally accepted real               
          property valuation rules".  Sec. 20.2032A-4(d), Estate Tax Regs.            
          Factors to be considered in such a determination include, but are           
          not limited to, whether the property is situated in the same                
          locality as the specially valued property; whether the property             
          is segmented or unified; whether the property is subject to                 
          flooding; and, in the case of timberlands, the comparability of             
          the timber to the timber located on the property to be specially            
          valued.  Sec. 20.2032A-4(d), Estate Tax Regs.                               
               Frazer utilized 8 timberland properties as comparables in              
          his report.  The report identified the lessor and lessee, the               
          location of the property, the initial year of the lease, and the            
          cash consideration paid for each of the 8 properties used as                
          comparables.  The report also listed the "Adjusted Net Lease                
          Income/Acre" for the 8 properties and the "Average" thereof                 
          ($15).  The report indicated no adjustments to any of the 8                 
          properties used as comparables based on the factors set forth in            
          section 20.2032A-4(d), Estate Tax Regs.                                     
               For the following reasons, we conclude that the report is              
          completely unreliable as to whether any of the 8 properties were            
          indeed comparable to the subject property.  The putative                    
          comparables ranged in size from 44 acres to 34,365 acres, yet no            




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