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rather than an accurate calculation of the cash rents required
thereunder.
As a further indication of his report's unreliability,
Frazer testified that the adjusted net lease income per acre
figures for each of the 8 properties used as comparables were not
used to derive an average gross cash rental for the 5 years
preceding decedent's death, despite the fact that section
2032A(e)(7)(A) expressly requires this to be done. Rather,
Frazer explained that the $15 per acre "Average" used to
calculate the special use value of the subject property was an
amount based on his "personal knowledge". Frazer stated that "I
chose what I thought would be the indicated market rent for what
I knew about the whole business, and that's it." Frazer conceded
that his report failed to adequately explain the $15 figure.
Petitioner attempts to gloss over the report's fundamental flaws
by stating that "Based on * * * [Frazer's] knowledge and
experience in valuing timberland, the $15 per acre rate was the
appropriate valuation rate within this range." However, an
amount that Frazer himself termed a "judgment call" does not
suffice for purposes of satisfying the stringent terms of section
2032A(e)(7)(A). See Martin v. Commissioner, 783 F.2d at 84.
Finally, Frazer testified that he validated his estimate of
the cash rental rate for the Cane Mill timberland by reference to
the prevailing rental rate for cropland during the relevant
period. However, there is no evidence in the record as to how
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