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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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