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labeled "qualified woodland" election does not apply to timber
valued by reference to the standard woodlands lease. We conclude
that the rent on the comparable land incorporates the value of
the timber standing in 1992 because it pays for the right to
harvest all timber grown during the term of the lease.
Consequently, we hold that petitioner can value the timberland
and standing timber under the provisions of section 2032A(e)(7).
IV. Pastureland
Petitioner asserts that the formula method under section
2032A(e)(7) should also be applied to the portion of the estate’s
timberland which was in cleared pasture and suitable for a new
stand of timber. Respondent contends that the pastureland must
be valued using the five factor method of section 2032A(e)(8).
The parties stipulated that the Woodward parcel, which was
in pasture (and therefore suitable for a new stand of timber),
constitutes "qualified woodland". Consequently, we find that
petitioner has provided comparable real property from which to
value the Woodward tract, which was in pasture.
The following three parcels of pastureland did not
constitute "qualified woodland":
Tract Valuation Elected
Lanford A 150 acres - pasture
Lanford B 125 acres - pasture
Patterson 65 acres - pasture
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