- 12 - 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 itPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011