- 26 - Petitioner's Federal estate tax return reported four tracts of land, aggregating only 137.5 acres, as being subject to a mortgage. A comparison of the description of these tracts on petitioner's return with the Land Bank mortgage reveals that two of the tracts reported on the return–-tract 1102, containing 13.33 acres, and tract 1103, containing 26.66 acres--were subject to the Land Bank mortgage. The other two tracts-–tracts 1201 and 1202, containing 97.5 acres--were not subject to the mortgage. Decedent's estate therefore included an interest in two tracts of the family farm land subject to the Land Bank mortgage: tracts 1102 and 1103, aggregating 40 acres. With respect to the value of the two tracts subject to the mortgage, petitioner's estate tax return reported a separate value for only one of these tracts: A value of $22,661, for tract 1103, or a reported value of $850 per acre. The return did not report a separate value for the other tract, tract 1102; instead, it reported an aggregate value of $78,790, for tracts 1102, 1201, and 1202. These three tracts aggregated 110.83 acres; their reported value was therefore $711 per acre. The value of the security for the Land Bank loan included in decedent's estate was $32,138, calculated as follows: $22,661 for tract 1103 plus $9,477 for tract 1102 ($711 per acre multiplied by 13.33 acres).Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011