Estate of Lewis S. Thompson, III, Deceased, Synovus Trust Company, Successor Executor To Security Bank and Trust Company - Page 7

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          perfect its protective election for special use valuation.  On              
          Schedule A-1, petitioner claimed a special use value for the                
          qualified woodlands in the amount of $375,711 (compared to the              
          woodlands' reported FMV of $2,028,730).  The remainder of the               
          Cane Mill property was reported at its FMV of $853,270.                     
               On the Schedule A attached to the amended return, petitioner           
          reported a total value of $2,132,000 for the Cane Mill property.            
          This amount represents the FMV of Cane Mill as reported on the              
          original return, $2,882,000, less $750,000, the maximum allowable           
          reduction for special use valuation under section 2032A.  See               
          sec. 2032A(a)(2).  Furthermore, on Schedule J of the amended                
          return, petitioner increased the amount of its section 2053(a)(2)           
          interest expense deduction with respect to funds borrowed from              
          the Trust to a total of $265,754.  In connection with these                 
          amendments, petitioner claimed a refund for an overpayment of               
          estate tax in the amount of $369,248 on line 28 of the amended              
          return.                                                                     
               Respondent issued a statutory notice of deficiency to                  
          petitioner on April 23, 1996.  Among other adjustments to                   
          decedent's gross estate, respondent disallowed the interest                 
          expense deduction in its entirety.  Respondent further disallowed           
          the deduction for alimony paid to decedent's former spouse to the           
          extent it exceeded $400,000.  (Petitioner has conceded that the             
          proper amount of the alimony deduction is $400,000.)  Respondent            






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