Estate of Carolyn J. Rogers - Page 42




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          Petitioner has failed to provide sufficient information from                
          which to make a valuation of pastureland that does not constitute           
          "qualified woodland" under the formula method.  Section 20.2032A-           
          4(a) and (b)(2), Estate Tax Regs., requires that, if the estate             
          desires valuation under section 2032A(e)(7), the executor must              
          provide to the Internal Revenue Service leases of actual                    
          comparable property and the cash rental from the property.                  
          Although the record does contain a copy of a lease on clear land            
          in Sumter County, petitioner has not satisfied us that this is              
          comparable pastureland.  Consequently, petitioner failed to                 
          satisfy the requirement to provide comparable leases and                    
          establish rental values of comparable pasturelands in order to              
          specially value decedent's pastureland under section 2032A(e)(7).           
          Consequently, there is no justification or basis for a section              
          2032A(e)(7) valuation of the pastureland located on the Lanford             
          A, Lanford B, and Patterson tracts.                                         
               Since the Woodward parcel of pastureland constitutes                   
          "qualified woodland", we hold that it may also be valued under              
          the provisions of section 2032A(e)(7).  Furthermore, we hold that           
          the three parcels of pastureland that did not constitute                    
          "qualified woodland", located on the Lanford A, Lanford B, and              
          Patterson tracts, must be valued under the provisions of section            
          2032A(e)(8).                                                                








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