Estate of Rebecca A. Wineman - Page 12




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          without question.  Decedent did not tell her children how she               
          calculated the rent.  In 1989, 1990, and 1991, the fair market              
          rent for the ranch properties was $16,595 per year, net of                  
          property taxes.                                                             
               Coastal Ranches contributed an unspecified amount of labor             
          and materials in connection with its lease of decedent's ranch              
          properties.  During 1989, 1990, and 1991, Coastal Ranches paid              
          property taxes, maintained fences, and paid utilities and other             
          expenses associated with the Wineman properties.                            
               In 1989, 1990, and 1991, decedent gave $10,000 in cash to              
          each of her three children.                                                 
          The Special Use Valuation Election                                          
               On its Form 706, U.S. Estate (and Generation-Skipping                  
          Transfer) Tax Return, petitioner claimed special use valuation              
          for parcels 5, 6, 7, 8, and 9, pursuant to section 2032A.  The              
          election reduced petitioner's reported gross estate by $750,000,            
          the maximum then permitted by law.                                          
               Respondent's estate tax attorney, Patricia Hiles (Ms.                  
          Hiles), sent a letter with an attached document request to the              
          attorney for the estate on September 13, 1995.  Paragraph 23 of             
          the document request stated:                                                
               The estate has submitted a one page computation of the                 
               Special Use Valuation which is not adequate to                         
               substantiate the special use valuation as required by                  
               IRS Regulations.  If the estate wishes to retain the                   
               special use valuation reduction, and not have it                       





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