Estate of Carolyn J. Rogers - Page 8




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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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