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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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