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(C) If the Court finds that petitioner may use section
2032A(e)(7) to value the timberland elected as section 2032A
property, but not the standing timber and pastureland, with
reference to the leases submitted by petitioner, the parties
agree that the valuations of decedent’s real estate are as
follows:
Egypt $104,797
Lanford A 662,264
Lanford B 195,045
Morgan 148,000
Woodward 77,305
Patterson 181,609
1,369,020
(3) In the event that the pastureland does not qualify for
section 2032A(e)(7) valuation, the value of the pastureland for
purposes of section 2032A(e)(8) is $350 per acre (less a 15-
percent discount for pasture in the Lanford A and Lanford B
tracts).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect as of the date of decedent’s
death, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Background
This case was submitted fully stipulated without trial
pursuant to Rule 122. The stipulation of facts and the
accompanying exhibits are incorporated herein by this reference
and are found accordingly.
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