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Respondent accepted the amended return but, relying on the
appraisals conducted by Dilmore and Young, subsequently
determined that the date-of-death values of decedent's one-half
interests in parcels A and B were $3,400,000 and $900,000,
respectively.
2. Trust Background
On December 17, 1963, decedent, Jack E. Held (Held), Leonard
M. Held, Sidney D. Held, and C. Ray Dudley (Dudley) entered into
a trust agreement in which Held and Dudley were named trustees
(trustees). Decedent held a one-half interest in the trust and
the remaining one-half interest was divided among the other
grantors. At the time the grantors created the trust, they
entered into an agreement to purchase certain real estate. A
principal purpose of holding the real estate in trust was to
facilitate sales of such property to interested purchasers.
The real estate acquired by the trust consisted of approximately
348 acres of unimproved land located in Jefferson County,
Alabama. The property purchased was not within the corporate
limits of any municipality. The tract was bisected by U.S.
Highway 280 (Highway 280) and was bound on its southwestern
border by Cahaba River Road.
Sometime during 1976, the State of Alabama condemned
approximately 113 acres of the property held in trust in order to
construct Interstate 459 (I-459). In an Alabama condemnation
proceeding the State gives notice of the condemnation and takes
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