- 55 - (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 sectionPage: Previous 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 Next
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