Estate of Lewis S. Thompson, III, Deceased, Synovus Trust Company, Successor Executor To Security Bank and Trust Company - Page 20

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          this comparison was made, or even that timberland and cropland              
          rental rates are in any way proximate.                                      
               In view of the foregoing, we conclude that petitioner has              
          failed to identify comparable real properties and cash rentals              
          therefor within the meaning of section 2032A(e)(7).  See sec.               
          20.2032A-4(b)(2), Estate Tax Regs.  As a result, petitioner has             
          not established the special use value of the Cane Mill                      
          timberland.  Sec. 20.2032A-8, Estate Tax Regs.  We hold,                    
          therefore, that petitioner has failed to perfect its protective             
          election for special use valuation under section 2032A;                     
          petitioner is required to value the entire Cane Mill property at            
          its undisputed FMV on the date of decedent's death; i.e.,                   
          $2,882,000.  Sec. 2031(a); see Estate of Strickland v.                      
          Commissioner, 92 T.C. at 33.                                                
               Because of our holding above, we need not consider whether             
          the subject property was in qualified use or whether decedent               
          materially participated in its operation.  See Estate of                    
          Strickland v. Commissioner, 92 T.C. at 33 n.12.                             
          II.  Section 2053 Administrative Expenses                                   
               Section 2053(a) provides in part that the value of a                   
          decedent's taxable estate shall be determined by deducting from             
          the value of the gross estate such amounts for administrative               
          expenses as are allowable by the laws of the jurisdiction under             
          which the estate is being administered.  Section 20.2053-3(a),              
          Estate Tax Regs., provides further that the                                 




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