Estate of Rebecca A. Wineman - Page 14




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          the 90-day period), petitioner, through its appraisal firm,                 
          Reeder, Gilman & Associates, submitted a section 2032A valuation            
          report.                                                                     
               The report listed 10 properties in the vicinity of                     
          decedent's ranch properties and listed the then-current rates of            
          rent, which ranged from $4.50 per acre to $15 per acre depending            
          upon the carrying capacity of the land.  The report did not set             
          forth the specific lease rates for any comparable properties in             
          the 5 years preceding 1992, but stated:                                     
               Rents for the land types on the subject have been                      
               static and current levels are representative of rents                  
               over the last five to ten years and are considered                     
               indicative of a five year average.                                     
          The report concluded:                                                       
                    Parcels 5, 6, and 9 are more arid and would                       
               compete relatively low in the range.  Parcel 7,                        
               although the net grazing land is of good quality,                      
               competes lower than Parcel 8 because the difficulty of                 
               the terrain reduces the carrying capacity. * * *                       
               Parcel 8 is good grazing and competes well above the                   
               Nipomo parcels and the San Luis Obispo Ranch.                          
          Petitioner's Special Use Valuation Report ultimately concluded              
          that rental values for the properties were:  $6 per acre for                
          parcels 5, 6, and 9; $7 per acre for parcel 7; and $8 per acre              
          for parcel 8.                                                               
               The report stated the following information with respect to            
          taxes:                                                                      
                    The Williamson Act, which governs the taxing of                   
               land in Ag Preserves, sets up a methodology for                        





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