Estate of Carolyn J. Rogers - Page 3




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               (2) If petitioner can value one or more tracts of the                  
          property under section 2032A(e)(7), which of the following                  
          valuation procedures applies:                                               
               (A) Can petitioner value all of the tracts as section                  
          2032A(e)(7) property, including timberland, standing timber, and            
          pastureland, using the leases submitted by petitioner; or                   
               (B) can petitioner value the timberland and standing timber            
          as section 2032A(e)(7) property, but not the pastureland, using             
          the leases submitted by petitioner; or                                      
               (C) can petitioner value only the timberland as section                
          2032A(e)(7) property, and not the standing timber and                       
          pastureland, using the leases submitted by petitioner?                      
          The second question requires a determination of whether the                 
          leases submitted by petitioner established a rental value:  (1)             
          For timberland, standing timber, and pastureland, (2) for                   
          timberland and standing timber only, or (3) for timberland only.            
               The parties have stipulated the following values for the               
          preceding issues (values include both elected property specially            
          valued under section 2032A and nonelected property at fair market           
          value):                                                                     
               (1) If the Court finds that petitioner must use section                
          2032A(e)(8), the parties agree that the values of decedent’s real           
          estate are as follows:                                                      







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