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preceding the year of the decedent's death. Sec. 20.2032A-
4(b)(2)(i) and (iv), Estate Tax Regs.
The determination of whether property is comparable is a
factual one and is made according to "generally accepted real
property valuation rules". Sec. 20.2032A-4(d), Estate Tax Regs.
Factors to be considered in such a determination include, but are
not limited to, whether the property is situated in the same
locality as the specially valued property; whether the property
is segmented or unified; whether the property is subject to
flooding; and, in the case of timberlands, the comparability of
the timber to the timber located on the property to be specially
valued. Sec. 20.2032A-4(d), Estate Tax Regs.
Frazer utilized 8 timberland properties as comparables in
his report. The report identified the lessor and lessee, the
location of the property, the initial year of the lease, and the
cash consideration paid for each of the 8 properties used as
comparables. The report also listed the "Adjusted Net Lease
Income/Acre" for the 8 properties and the "Average" thereof
($15). The report indicated no adjustments to any of the 8
properties used as comparables based on the factors set forth in
section 20.2032A-4(d), Estate Tax Regs.
For the following reasons, we conclude that the report is
completely unreliable as to whether any of the 8 properties were
indeed comparable to the subject property. The putative
comparables ranged in size from 44 acres to 34,365 acres, yet no
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