Estate of Pattie Welder Edwards - Page 6




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          consecutive 5-year options to renew the lease at a fair market              
          rental value.  The postdeath lease set the initial rent at $7.50            
          per acre annually and $12,000 annually per each residence located           
          on the land.  The postdeath lease on the Cotulla Ranch allowed              
          hunting on the leased properties with the express written consent           
          of the lessors.  Hunting had been prohibited in all prior written           
          leases because decedent was adamant that the ranchlands would not           
          be used for hunting.                                                        
               The estate reported the fair market value of the Sinton                
          Ranch at $2.6 million on its Form 706, United States Estate (and            
          Generation-Skipping Transfer) Tax Return, Schedule A, Real                  
          Estate.  The real estate appraisal report that was prepared by              
          Thomas F. Dorsey (Dorsey) and submitted with the estate’s Form              
          706 concluded that the unencumbered fair market value of                    
          decedent’s interest in the Sinton Ranch on decedent’s date of               
          death was $4,150,000 and that the fair market value of the Sinton           
          Ranch encumbered by the postdeath lease was $3,350,000.  In the             
          notice of deficiency, respondent determined that the fair market            
          value of the Sinton Ranch on the date of decedent’s death was               
          $4,150,000.  Respondent reduced the value by $750,000 for a valid           
          election under section 2032A.                                               
               The estate reported the fair market value of the interest in           
          the Cotulla Ranch on Form 706, Schedule A, at $1,070,000.  The              
          real estate appraisal report that was prepared by Dorsey and                






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