- 26 - 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;Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011