- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011