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method and value the property under section 2032A(e)(7) if it
establishes the annual gross cash rental of comparable land for
the 5 calendar years ending before the date of decedent’s death
within the meaning of section 2032A(e)(7).
In order to satisfy the comparable land requirement under
section 2032A(e)(7), on August 31, 1998, petitioner identified
seven tracts of land which it asserted were comparable to
decedent’s lands which are specially valued. In addition, the
record contains a copy of a lease on clear land in Sumter County.
Petitioner engaged Dr. Harry L. Haney to determine the
comparability of the seven tracts of land with the five estate
tracts of specially valued land. The record contains detailed
descriptions of the seven tracts of land that petitioner asserts
are comparable to the five estate tracts in the leases and in Dr.
Haney's reports.
Dr. Haney provided both an original and a supplemental
report. The parties agree that these reports are accepted as if
the author had testified to their contents. Dr. Haney based his
opinion on his experience as a forest economist, professor of
forest management-economics at the Virginia Polytechnic Institute
and State University in Blacksburg, Virginia, and owner of
Alabama timberland. Dr. Haney has lectured, taught, and written
extensively on the subjects of forestry and is a Registered
Forester in the State of Alabama. His graduate degrees include a
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