Estate of Carolyn J. Rogers - Page 24




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          the five factor method of section 2032A(e)(8).  See sec.                    
          2032A(e)(7)(C).                                                             
               B. Section 2032A(e)(8)6--The Five Factor Method                        
               The second valuation method is set forth under section                 
          2032A(e)(8).  This method is based upon the application of five             


               6     SEC. 2032A(e).  Definitions; Special Rules.–For                  
               purposes of this section–                                              
                              *   *   *   *   *   *   *                               
                         (8)  Method of valuing closely held business                 
                    interests, etc.-–In any case to which paragraph (7)(A)            
                    does not apply, the following factors shall apply in              
                    determining the value of any qualified real property:             
                              (A) The capitalization of income which the              
                         property can be expected to yield for farming or             
                         closely held business purposes over a reasonable             
                         period of time under prudent management using                
                         traditional cropping patterns for the area, taking           
                         into account soil capacity, terrain configuration,           
                         and similar factors,                                         
                              (B) The capitalization of the fair rental               
                         value of the land for farmland or closely held               
                         business purposes,                                           
                              (C) Assessed land values in a State which               
                         provides a differential or use value assessment              
                         law for farmland or closely held business,                   
                              (D) Comparable sales of other farm or closely           
                         held business land in the same geographical area             
                         far enough removed from a metropolitan or resort             
                         area so that nonagricultural use is not a                    
                         significant factor in the sales price, and                   
                              (E) Any other factor which fairly values the            
                         farm or closely held business value of the                   
                         property.                                                    





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