Estate of Walter F. Klosterman, Deceased Kent Klosterman Alan Klosterman, Personal Representatives v. Commissioner Internal Revenue Service

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 this formula, the estate excluded from the average annual gross cash rental the average annual amounts of irrigation assessments…