- 44 - therefore, we deny respondent’s motion and admit the subject reports. C. Requirements for Special Use Valuation Only one of the requirements for a valid section 2032A election is at issue here; i.e., the requirement that a notice of election contain the method of valuation based on use. See sec. 20.2032A-8(a)(3)(viii), Estate Tax Regs. Section 2032A(e)(7) provides the general formula and method to be used in valuing farm property: (7) Method of valuing farms.-- (A) * * * the value of a farm for farming purposes shall be determined by dividing–- (i) the excess of the average annual gross cash rental for comparable land used for farming purposes and located in the locality of such farm over the average annual State and local real estate taxes for such comparable land, by (ii) the average annual effective interest rate for all new Federal Land Bank loans. For purposes of the preceding sentence, each average annual computation shall be made on the basis of the 5 most recent calendar years ending before the date of the decedent’s death. * * * * * * * (C) Exception.-–The formula provided by subparagraph (A) shall not be used-– (i) where it is established that there is no comparable land from whichPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
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