Estate of Carolyn J. Rogers - Page 20




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          purpose of the special use valuation provision is to reduce the             
          estate tax burden, thereby alleviating liquidity problems faced             
          by the surviving family of a person who died owning real property           
          used as a farm or in a closely held business.  See H. Rept. 94-             
          1380, at 21-22 (1976), 1976-3 C.B. (Vol. 3) 735, 755-756; see               
          also S. Rept. 94-938 (Part 2), at 15 (1976), 1976-3 C.B. (Vol.3)            
          643, 657.  Congress sought to allow the family to continue                  
          operating the farm or other business, rather than force the sale            
          of the land to pay estate taxes.  See Estate of Mapes v.                    
          Commissioner, 99 T.C. 511, 516-517 (1992); Estate of Thompson v.            
          Commissioner, T.C. Memo. 1998-325.; H. Rept. 94-1380, supra at              
          21-22, 1976-3 C.B. (Vol. 3) at 755-756; S. Rept. 94-938 (Part 2),           
          supra at 15, 1976-3 C.B. (Vol. 3) at 657.                                   
               Additionally, the benefit afforded by section 2032A is not             
          open ended; the maximum aggregate reduction in value allowable by           
          the statute for qualified real property with respect to any                 
          decedent is $750,000.  See sec. 2032A(a)(2).                                
               Farms may be specially valued under section 2032A by using             
          one of two methods, the formula method under section 2032A(e)(7)            
          or the five-factor method under section 2032A(e)(8).                        













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