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assistance to the Court, it will be given little weight. See
Laureys v. Commissioner, 92 T.C. 101, 129 (1989).
In litigation, the parties have used different approaches to
valuing the real property. Petitioner’s expert used comparables
to provide a cash sale price of land for residential development
properties. Petitioner’s expert then applied substantial
discounts (as much as 80 percent), reducing an average of the
comparable sales to a proposed value of $25,000 per acre.
Petitioner’s trial expert’s $25,000 value is $114,500 less than
the $139,500-per-acre value that had been reported on the
estate’s tax return. Respondent’s expert was asked to derive a
per-acre value based on the June 1994 agreement. After reaching
a value based on the agreement, he discounted it to account for
the delay in the closing of the transaction. Respondent uses the
resulting value as an actual and comparable sale price for the
Busch property. Although the two approaches reached disparate
results, both are sourced in traditional cash sale principles
involving the use of comparables and may be reconciled.
In addition to the experts called by the parties for trial,
we must consider petitioner’s appraiser’s report attached to the
estate tax return. We find analysis of that estate tax return
appraisal necessary because its per-acre value ($139,500) is more
closely allied with contract price ($150,000) and respondent’s
determination. In addition, the $139,500 value is substantially
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