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provisions of section 2032A. These five tracts of specially
valued estate property are collectively referred to as the five
estate tracts. The five estate tracts, located in Sumter County,
Alabama, are as follows:
Tract Valuation Elected
Egypt 215 acres - land and timber
Lanford A 90 acres - land and timber
435 acres - land (no timber election)
190 acres - land (no timber election)
805 acres - land and timber
150 acres - pasture
Lanford B 125 acres - pasture
Woodward 40 acres - land and timber
100 acres - pasture
Patterson 65 acres - pasture
On the estate tax return, petitioner timely elected and
qualified for a "qualified woodland" election pursuant to section
2032A(e)(13) for the following properties:
Tract "Qualified Woodland" Election
Egypt 215 acres - land and timber
Lanford A 90 acres - land and timber
805 acres - land and timber
Woodward 40 acres - land and timber
100 acres - pasture
On the estate tax return, petitioner elected to value the
land under section 2032A(e)(8). Respondent valued the property
at a higher value under section 2032A(e)(8) and ultimately issued
a notice of deficiency determining the value of the property at
the higher value. Petitioner now seeks to value the property
under section 2032A(e)(7). Petitioner may change the valuation
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Last modified: May 25, 2011