The decedent's estate held three tracts of land that were part of five contiguous parcels. If the tracts could be combined, they could be developed. But, without that combining, it was not economically feasible to develop the tracts. There current zoning was for agricultural use. The other two parcels were owned by an entity that the decedent owned 28 percent of. The IRS took the position that the estate's land value should be its value reflecting its develop potential on the basis that it was likely that the properties could be combined such that a willing buyer would value the property at its developmental potential value. The Tax Court determined that federal law governed the valuation issue and rejected the IRS position. The IRS failed to show that there was a reasonable probability that the tracts could be combined in the near future, and that the presumption was with the estate that the decedent was using the land for its highest and best use at the time of death. The court noted that the argument that the land would be worth more if the tracts were combined was not a relevant fact in determining if assembling the tracts together would occur. The court also rejected the IRS argument that the estate's minority interest in the entity and relationships with the other owners required combination of the tracts. There was no evidence that the decedent's estate controlled the entity. Estate of Pulling v. Comr., T.C. Memo. 2015-134.