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Colleton County was ranked 21st in population growth in
South Carolina, with an 11.3-percent increase during the period
1990 through 2000. There are neither zoning nor use restrictions
in Colleton County.
The parties stipulate that DP comprises 2,095.12 acres. The
record establishes that the main tract is 1,931.30 acres, and the
five smaller tracts total 133.82 acres.2 DP is north of U.S.
Highway 17 and south of the Ashepoo River and is bisected east to
west by Clover Hill Road. DP features timberlands, open fields,
access to a shallow branch of the Ashepoo River, and 226 acres of
what were historically rice fields. The rice fields have not
functioned as such for decades and no longer have dikes to
regulate water flow from tidal changes. DP is inhabited by an
array of wildlife including deer and migratory water fowl.
Procedural History
On September 30, 2003, respondent issued a notice of
deficiency in which he determined a Federal estate tax deficiency
of $843,146. The deficiency included three increases to the
value of decedent’s taxable estate: (1) A $157,500 increase to
the fair market value of decedent’s residence; (2) a $1,112,979
increase to the fair market value of DP (a total value of
$5,490,992); and (3) a $390,315 increase for the disallowance of
executor’s commissions and attorneys’ fees.
2The record does not explain the 30-acre discrepancy.
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Last modified: May 25, 2011