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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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