- 42 - 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).Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
Last modified: May 25, 2011