Estate of Carolyn J. Rogers - Page 23




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               This average rent amount is then divided by a capitalization           
          factor based on the average annual effective interest rate for              
          all new Federal Land Bank loans.  The average annual computation            
          is performed on the basis of the 5 most recent calendar years               
          ending before the date of the decedent's death.  See sec.                   
          2032A(e)(7)(A); sec. 20.2032A-4(a), Estate Tax Regs.                        
               The annual gross cash rental is the amount of cash rental of           
          actual tracts of comparable farmland in the same locality, not              
          reduced by any expenses or liabilities associated with the farm.            
          See sec. 20.2032A-4(b)(1), Estate Tax Regs.  The executor is                
          required to identify actual comparable property and the cash                
          rentals from the comparable property for all of a decedent's                
          property that is specially valued.  See Estate of Strickland v.             
          Commissioner, 92 T.C. 16, 24 (1989).  The regulations require               
          that the executor be able to substantiate the valuation with                
          supporting documentation, including identification of comparable            
          property and cash rentals from that property.  See sec. 20.2032A-           
          4(b)(2)(i), Estate Tax Regs.                                                
               Section 2032A(e)(7) provides that the value of a farm for              
          farming purposes shall be determined by the formula method of               
          valuation unless:  (1) It is established that there is no                   
          comparable land from which the average annual gross cash rental             
          or average net share rental can be determined; or (2) the                   
          executor elects to have the value of the farm determined under              






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