- 13 - denied, then we will need the following within the next 60 days: a. Who did this calculation submitted with the 706? b. If there are any other data to support it, please submit copies. c. It appears that the valuation is based upon what deceased received on her ranching operations. Please supply copies of those leases. d. Please comply with Regulation 20.2032A-4 (copy enclosed for your convenience) that requires documentation which identifies specific comparable rentals and taxes for five years prior to date of death, arms length transactions, to determine the net rents. (I am also enclosing a copy of the Tax Management discussion and example of how special valuations must be done in order to qualify.) The Farm Credit Bank rate for the Sacramento District for 1992 was 11.50%. (See copy of Revenue Ruling 92-12 enclosed.) A rate cannot be “assumed”. e. If the appropriate documentation for the special use valuation is not supplied, the $750,000 reduction will be disallowed, see Strickland, 92 TC 16, copy enclosed. At a meeting with the estate's attorney, Richard Weldon, and the coexecutors on September 21, 1995, Ms. Hiles described the requirements of electing special use valuation pursuant to section 2032A(e)(7). Ms. Hiles did not mention section 2032A(e)(8) because she did not believe the estate could properly elect special use valuation under that section. After the meeting, Ms. Hiles extended the period for supplying the requested information to 90 days. On December 12, 1995 (withinPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011