- 20 - 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).Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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