- 19 - The average annual State and local real estate taxes paid on the five leased tracts for the 5 years preceding decedent’s death were $1.1592 per acre. The average annual effective interest rate for all new Federal Land Bank loans for the 5 years preceding decedent's death was 10.21 percent. Discussion I. Overview of Section 2032A–-Special Use Valuation Generally, a decedent's gross estate includes the fair market value of the decedent's interest in all property in which the decedent owned an interest at the time of death. See secs. 2031, 2033; sec. 20.2031-1(b), Estate Tax Regs. However, in the case of certain real property used by the decedent or a member of the decedent's family for farming or in a closely held business, section 2032A allows the decedent's personal representative to elect to value the real property on the basis of its value as a farm or in a closely held business, rather than the fair market value of the property determined on the basis of its "highest and best use". Sec. 20.2032A-3(a), Estate Tax Regs.; see sec. 2032A(a)(1), (e)(7) and (8); see also Stovall v. Commissioner, 101 T.C. 140, 146 (1993); Estate of Thompson v. Commissioner, T.C. Memo. 1998-325. Section 2032A was added to the Code by the Tax Reform Act of 1976, Pub. L. 94-455, sec. 2003, 90 Stat. 1520, 1856. ThePage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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