- 39 - IV. The Special Use Valuation A. Introduction The last issue for decision concerns petitioner’s election to value the interests in certain ranch properties under section 2032A. On its Form 706, petitioner elected special use valuation for several properties, claiming that it is entitled to the $750,000 reduction in value for special use under section 2032A. Respondent contends that petitioner may not take advantage of section 2032A because it failed to comply with the statutory and regulatory requirements for an election pursuant to that section. Section 2032A allows an executor to elect to value real property on the basis of its value for farming purposes rather than its fair market value. See Stovall v. Commissioner, 101 T.C. 140, 146 (1993); sec. 20.2032A-3(a), Estate Tax Regs. A reduction of up to $750,000 is permitted.16 See sec. 2032A(a)(2). Congress enacted the provisions allowing special use valuation with the goal of reducing the estate tax burden on small family farms and businesses, thereby limiting the liquidity problems and forced sales of those businesses, with the ultimate goal of allowing continued family operation of the qualifying farms and 16Sec. 501(b) of the Taxpayer Relief Act of 1997, Pub. L. 105-34, 111 Stat. 846, amended sec. 2032A(a) to provide an adjustment for inflation, effective for estates of decedents dying after Dec. 31, 1997. As decedent died before the effective date, the adjustment for inflation is not applicable.Page: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
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