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valuation factors. The five factors set forth in section
2032A(e)(8) are: (1) The capitalization of income which the
property can be expected to yield for farming purposes; (2) the
capitalization of the fair rental value of the land for farmland;
(3) the assessed land value for ad valorem real estate tax
purposes; (4) the sale price of comparable parcels of farmland in
the geographic area; and (5) any other factor which fairly values
the farmland.
Valuation under the five factor method of section
2032A(e)(8) is required under certain circumstances. If rents
for comparable property are not available, then petitioner must
use section 2032A(e)(8) to value the property. See sec.
20.2032A-4(a), Estate Tax Regs.
II. Comparable Land
Petitioner asserts that the five estate tracts and the five
leased tracts are "comparable land". Respondent contends that
the five estate tracts and the five leased tracts are physically
comparable as to land only and that the five estate tracts and
the five leased tracts are not comparable in any manner in regard
to timber volumes, timber quality, and timber quantity, and to
rental values.
In order to use section 2032A(e)(7), the estate must
identify "comparable land". The Oxford English Dictionary
(1993), the Merriam-Webster’s Collegiate Dictionary (10th ed.
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