- 20 - 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 thePage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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