Estate of Lewis S. Thompson, III, Deceased, Synovus Trust Company, Successor Executor To Security Bank and Trust Company - Page 13

                                       - 13 -                                         
               From the average annual gross cash rental, as above                    
          computed, the average annual State and local real estate taxes              
          for the comparable land is subtracted.  The result of the                   
          subtraction is then divided by the average annual effective                 
          interest rate for all new Federal Land Bank loans.  Sec.                    
          2032A(e)(7)(A).  (The IRS issues an annual revenue ruling setting           
          forth the effective interest rate for each of the regional                  
          Federal Land Bank Districts.  The effective interest rate for the           
          Columbia Farm Credit Bank district in which the respective                  
          property is located was 10.87 percent for 1992.  Rev. Rul. 92-12,           
          1992-1 C.B. 311.)  The quotient resulting from the foregoing                
          division is the special use value of the qualified real property.           
          Petitioner claims to derive its special use value of the                    
          subject property from the annual cash rental value of $15 per               
          acre set forth in the May 10, 1993, special use valuation report            
          (report) of its expert, Frazer.  (We note that the figure of                
          $375,711 reported on the amended return appears nowhere in                  
          Frazer's report, nor has the Court been able to determine how               
          such a special use value was reached by petitioner.  Based on our           
          calculations, and assuming for this purpose only that Frazer's              
          $15 per acre cash rental value for the subject property is                  
          correct, 2,929.1 acres of qualified woodlands times $15 per acre,           
          without subtracting property taxes (Frazer stated that these were           
          usually paid by lessees in these types of leases, so it is                  
          assumed that Frazer's $15 per acre is a net figure), equals                 




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