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After a concession by petitioner, the issues for decision
are as follows:
(1) Whether petitioner is entitled to value certain real
property owned by Lewis S. Thompson, III, (decedent), at the time
of his death pursuant to the special use valuation provisions of
section 2032A; and (2) whether petitioner incurred an interest
expense which is deductible under section 2053(a)(2).
All section references are to sections of the Internal
Revenue Code in effect at decedent's date of death, unless
otherwise indicated. All Rule references are to the Tax Court
Rules of Practice and Procedure.
Some of the facts have been stipulated and are so found.
The stipulated facts and attached exhibits are incorporated
herein by this reference. Synovus Trust Company (Synovus),
successor executor to Security Bank and Trust Company, had its
principal place of business in Albany, Georgia, at the time the
petition was filed.
FINDINGS OF FACT
Decedent died testate on February 19, 1992. At the time of
his death, decedent resided in Albany, Georgia. Decedent was
divorced, and was survived by his four adult children and a
brother.
The reported value of decedent's total gross estate at the
date of his death, as adjusted under section 2032A(b)(3)(A), was
$5,439,313. Among the assets included in decedent's gross estate
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