Estate of Ona E. Hendrickson - Page 26




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               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).                                                  








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