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Petitioner’s primary expert witness is Noel K. Atkinson,
hereinafter sometimes referred to as Atkinson. He has been a
real estate appraiser since the early 1950's. When the instant
case was tried, about half of Atkinson’s work was testifying in
Court.
Atkinson appropriately used the comparable sales approach as
a major element in valuing the land portion of each of the
Subject Properties.13 Under the comparable sales approach, if a
comparable property has an element of a lesser quality than the
property being appraised, then the comparable property’s sale
price is adjusted upward, and vice versa. Atkinson appropriately
compared several different elements of the properties and
generally used four to six comparables. He displayed the
adjustments in a matrix, and also briefly explained why he
adjusted the comparable property’s sale price up or down.
13 The comparable sales approach involves locating parcels of
land which were as physically similar as possible to the subject
property, and which had been sold within a reasonable time of
decedent’s death. Since no two sales and no two parcels are
identical, the actual sales price in each case is then to be
adjusted up or down to reflect the differences between the
subject property and the comparable property. The estimated
values of the comparable properties as so adjusted provide an
indication of the value of the subject property on the relevant
date. Like most valuation techniques, this method is far from an
exact science. However, it is based upon the common sense
approach of taking the actual sales prices of properties similar
to the subject properties and then relating the prices to the
subject properties. This Court has often used or approved the
use of this valuation method. See Wolfsen Land & Cattle Co. v.
Commissioner, 72 T.C. 1, 18-21 (1979).
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