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based, is not reliable because it fails to differentiate
between so-called dry land and wetland.
Section 2031(a) requires the "gross estate" of the
decedent to be determined for Federal estate tax purposes,
"by including * * * the value at the time of his death of
all property, real or personal, tangible or intangible,
wherever situated." All section references are to the
Internal Revenue Code as in effect for 1990. The fair
market value of property included in a decedent's gross
estate is "the price at which the property would change
hands between a willing buyer and a willing seller, neither
being under any compulsion to buy or to sell and both
having reasonable knowledge of relevant facts." Sec.
20.2031-1(b), Estate Tax Regs. This requires property to
be valued from the viewpoint of a hypothetical buyer and
seller, each of whom would seek to maximize his or her
profit from any transaction involving the property. See
Estate of Watts v. Commissioner, 823 F.2d 483, 486 (11th
Cir. 1987), affg. T.C. Memo. 1985-595; Estate of Bright v.
United States, 658 F.2d 999, 1005-1006 (5th Cir. 1981).
The value of property as of a particular date is a question
of fact. E.g., Hamm v. Commissioner, 325 F.2d 934, 938
(8th Cir. 1963), affg. T.C. Memo. 1961-347; Messing v.
Commissioner, 48 T.C. 502, 512 (1967). A sound valuation
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