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20.2032-4(d), Estate Tax Regs. For decedent’s estate, the range
in size of comparables is much tighter: comparables of 261 to
1,665.28 acres (for subject properties ranging from 65-1670
acres). Furthermore, Dr. Haney excluded potential comparables
because of differences in location, land quality, and timber
type/maturity. Dr. Haney excluded the potential comparable in
Fayette County because of location; he excluded a Pickens County
tract with somewhat different slope and soil. Further, Dr. Haney
proposed a 10-percent reduction to four of the subject
properties, because of the superior quality of timber on the five
leased tracts. As noted previously, however, such a reduction is
inappropriate as appraisals are not true measures of the actual
cash rental value of comparable property. Moreover, petitioner
provided detailed descriptions of the subject properties and the
leased properties in the original estate tax return; more
detailed descriptions of the leased properties are provided in
the leases and Dr. Haney's reports.
The eight leases in Estate of Thompson were entered into
over a 27-year period, some with no rent escalation clause. For
those leases with no rent escalation clause, the expert claimed
to have applied the "Producer Price Index" (PPI) in an effort to
calculate the market rental value of those properties for the 5-
year period preceding decedent’s death. Petitioner requested
that we take judicial notice of Report 807, Escalation and
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