Estate of Rebecca A. Wineman - Page 13




                                       - 13 -                                         

               denied, then we will need the following within the next                
               60 days:                                                               
                    a.  Who did this calculation submitted with the                   
                    706?                                                              
                    b.  If there are any other data to support it,                    
                    please submit copies.                                             
                    c.  It appears that the valuation is based upon                   
                    what deceased received on her ranching operations.                
                    Please supply copies of those leases.                             
                    d.  Please comply with Regulation 20.2032A-4 (copy                
                    enclosed for your convenience) that requires                      
                    documentation which identifies specific comparable                
                    rentals and taxes for five years prior to date of                 
                    death, arms length transactions, to determine the                 
                    net rents.  (I am also enclosing a copy of the Tax                
                    Management discussion and example of how special                  
                    valuations must be done in order to qualify.)  The                
                    Farm Credit Bank rate for the Sacramento                          
                    District for 1992 was 11.50%. (See copy of Revenue                
                    Ruling 92-12 enclosed.)  A rate cannot be                         
                    “assumed”.                                                        
                    e.  If the appropriate documentation for the                      
                    special use valuation is not supplied, the                        
                    $750,000 reduction will be disallowed, see                        
                    Strickland, 92 TC 16, copy enclosed.                              
               At a meeting with the estate's attorney, Richard Weldon, and           
          the coexecutors on September 21, 1995, Ms. Hiles described the              
          requirements of electing special use valuation pursuant to                  
          section 2032A(e)(7).  Ms. Hiles did not mention section                     
          2032A(e)(8) because she did not believe the estate could properly           
          elect special use valuation under that section.  After the                  
          meeting, Ms. Hiles extended the period for supplying the                    
          requested information to 90 days.  On December 12, 1995 (within             






Page:  Previous  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  Next

Last modified: May 25, 2011