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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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