Estate of Carolyn J. Rogers - Page 26




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          1998), and the American Heritage College Dictionary (3d ed. 1993)           
          define the word "comparable" as "able to be compared (with);                
          worthy of comparison; fit to be compared (to)," "capable of or              
          suitable for comparison," or "admitting of comparison with                  
          another or others."                                                         
               Section 20.2032A-4(d), Estate Tax Regs., defining                      
          "comparable real property," states that "Comparable real property           
          must be situated in the same locality as the specially valued               
          property."  In the case before us, location was the first                   
          consideration in determining the five leased tracts, as Dr. Haney           
          excluded one of the two other potential comparables based on                
          slightly greater distance.  The five estate tracts and the five             
          leased tracts are all located in the black belt soil area of                
          western Alabama along the Mississippi border.  Indeed, four out             
          of the five leased tracts are located in the same county as all             
          five estate tracts, and the fifth comparable is in the adjacent             
          Pickens County on the north.                                                
               Section 20.2032A-4(d), Estate Tax Regs., sets forth the                
          following factors as among those to be considered in determining            
          comparability:                                                              
                    (1) Similarity of soil as determined by any objective             
               means, including an official soil survey reflected in a soil           
               productivity index;                                                    
                    (2) Whether the crops grown are such as would deplete             
               the soil in a similar manner;                                          







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