Estate of Carolyn J. Rogers - Page 44




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          specially value decedent’s pastureland that did not constitute              
          "qualified woodland" under the provisions of section 2032A(e)(7).           
          As a result, 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).  Consequently, the value of              
          the pastureland for purposes of section 2032A(e)(8) is $350 per             
          acre (less a 15-percent discount for pastureland in the Lanford A           
          and Lanford B tracts).                                                      
               We have considered all other arguments advanced by the                 
          parties, and to the extent they are not addressed herein, we find           
          them to be neither relevant nor persuasive.                                 
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          





















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