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ESTATE OF KLOSTERMAN v. C.I.R. SERVICE

No. 93-70349.

32 F.3d 402 (1994)

ESTATE OF Walter F. KLOSTERMAN, Deceased; Kent Klosterman; Alan Klosterman, personal representatives, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided July 5, 1994.

Attorney(s) appearing for the Case

Donald J. Chisholm, Burley, ID, for petitioners-appellants.

Gary R. Allen, Tax Div., U.S. Dept. of Justice, Washington, DC, for respondent-appellee.

Before: WIGGINS and THOMPSON, Circuit Judges, and EZRA, District Judge.

DAVID R. THOMPSON, Circuit Judge:

The Estate of Walter F. Klosterman, deceased, elected to use the formula prescribed by 26 U.S.C. § 2032A(e)(7)(A) to value farmland for estate tax purposes. This section permits a taxpayer to value farmland by dividing the excess of the "average annual gross cash rental" received for comparable land over the "State and local real estate taxes" imposed upon such land, by the applicable Federal Land Bank interest rate. In applying...

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