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and the factors noted above, the five leased tracts (four of
which are located in Sumter County, Alabama) are highly
comparable to each of the five estate tracts--all of which are
located in Sumter County. Thus, we find and determine that the
five estate tracts and the five leased tracts are highly
comparable.
In Estate of Thompson v. Commissioner, T.C. Memo. 1998-325,
we concluded that the taxpayer had failed to identify comparable
real properties and cash rentals within the meaning of section
2032A(e)(7), where the expert’s adjusted net lease income per
acre figures were more akin to an appraisal, which is expressly
prohibited by section 20.2032A-4(b)(2)(iii), Estate Tax Regs.,
rather than an accurate calculation of actual cash rents.
In Estate of Thompson we concluded that the expert’s report
was completely unreliable as to whether any of eight properties
were indeed comparable to the subject property for the following
reasons. First, the alleged comparable properties ranged in size
from 44 acres to 34,365 acres, compared to the subject property
of 2,929 acres. In addition, the expert made no adjustments due
to differences in location, land quality, or timber
type/maturity. Moreover, no description of the properties was
contained in the expert’s report.
In decedent’s estate here, five out of seven tracts share
nine out of the nine applicable features set forth in section
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