The partnership is in the business of renting mini-storage spaces.  The partnership built the buildings etc on lease property in 1984.  The annual lease payment is $103,000.  The lease was for 30 years, ending October 2013.  All fixed assets reverts to the landowner on October 2013.

The value in the 706 was based on a rental income stream over 10 years (years 2003 - 2013).  The decedent died October 2003.

There are various fexed assets (building, etc) and improvements of $1.4 mil and accum depreciation of 1.3 mil; fully amortized software of $6,000 and cash of $40,000.

My research so far says I'm to allocate basis to cash, fixed assets, and intangibles and depreciated according to MACRS (39 years!). This would leave me with a lot of basis in fixed assets when the lease ends in 10 years. 

I am hoping for depreciation/amortization of a land lease of 10 years.

Thanks for your input.