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V. Conclusion
We find and conclude that the leases provided by petitioner
are leases of comparable land for the 5 most recent calendar
years ending before the date of decedent’s death. Consequently,
we hold that petitioner can value the timberland and standing
timber under the provisions of section 2032A(e)(7). 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).
As a result, the rent capitalization value is the excess of
(i) the average annual gross cash rents from the comparable five
leased tracts for the prior 5 years ($9.6964) over (ii) the
average annual State and local real estate taxes for the same
period ($1.1592), divided by (iii) the average annual interest
rate on Federal Land Bank loans for the same period (10.21
percent). The result is a per-acre rent capitalization value of
$83.6161.
Furthermore, the improvements located on the Lanford A and
Woodward tracts are valued at approximately $2,707 and $5,610,
respectively, according to the Butler & Gardiner appraisal. We
hold that these amounts should be added to the value of the land.
In addition, we find and conclude that petitioner failed to
satisfy the requirement to provide comparable leases and
establish rental values of comparable pasturelands in order to
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