Albert M. Graham and Martha A. Graham - Page 29

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          $425,637 ($325,637 for depreciable assets and $100,000 for land).           
          The balance sheet entries are a reasonable indicator of the fair            
          market value of the Riverside property on May 30, 1995, because             
          they were prepared relatively close in time to when the property            
          was placed in the partnership, were made long before the value of           
          the Riverside property was in issue, and were not made in                   
          anticipation of litigation.                                                 
               Third, Smith testified that he thought a one-half interest             
          in the Riverside property had a fair market value of $425,000               
          when negotiations between the parties in the Stover bankruptcy              
          ended in March 1995.  Smith based his estimate on his visit to              
          the property, the documents filed in the Stover bankruptcy, and             
          his discussions with the Anises.                                            
               Fourth, Stover listed a value of $400,000 for his one-half             
          interest in the Riverside property on a bankruptcy schedule he              
          filed in August 1993.  An owner of property is generally                    
          qualified to testify as to the property’s value.  Fed. R. Evid.             
          702; see LaCombe v. A-T-O, Inc., 679 F.2d 431, 435 (5th Cir.                
          1982); Estate of Dunia v. Commissioner, T.C. Memo. 2004-123.                
               We believe the balance sheets, Smith’s testimony, and the              
          Stover bankruptcy schedule, which all are in the same range                 
          ($400,000-425,000) for a one-half interest in the Riverside                 
          property, are entitled to more weight than petitioners’ expert’s            
          appraisal.  We conclude that the fair market value of the                   






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