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(D) Comparable sales of other farm or closely
held business land in the same geographical area
far enough removed from a metropolitan or resort
area so that nonagricultural use is not a
significant factor in the sales price, and
(E) Any other factor which fairly values
the farm or closely held business value of
the property.
The statute clearly provides that all factors shall apply,
joining them with the conjunction “and”. See Estate of Hughan v.
Commissioner, T.C. Memo. 1991-275. However, the factors used in
any given circumstance are limited to those which are relevant.
See id. Section 2032A(e)(8) prescribes a subjective method of
valuation, in contrast to the objective method of section
2032A(e)(7). See Estate of Klosterman v. Commissioner, 99 T.C.
313, 317 n.4 (1992), affd. 32 F.3d 402 (9th Cir. 1994). The
legislative history confirms that all relevant facts are taken
into account when the multiple factor method of valuation is
elected. See S. Rept. 94-938 (Part 2), at 15 (1976), 1976-3 C.B.
(Vol. 3) 643, 657; see also Estate of Hughan v. Commissioner,
supra.
In Estate of Hughan, the estate's section 2032A election was
disallowed on audit for failure properly to document comparable
property under the rules of section 2032A(e)(7). In accordance
with section 20.2032A-4(b)(2)(i), Estate Tax Regs., the Service's
examiner increased the value of the farmland pursuant to an
appraisal under the multiple factor method of section
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