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on its face, is both ambiguous and suspect. We do not even know
whether the Mark IV helmet that was the subject of the Hetz
report is in fact the Mark IV helmet at issue here. Nor can we
determine solely on the basis of the document in the record that
purports to be Mr. Hetz' resume whether Mr. Hetz was qualified to
prepare the report that was attached to petitioner's 1991 return.
In this connection, since petitioner did not offer Mr. Hetz as a
witness at trial, respondent did not have the opportunity to voir
dire Mr. Hetz on his qualifications as an expert or to examine
him on the Hetz report, nor did the Court have the opportunity to
question him about his qualifications as an expert in valuing the
Mark IV helmet at issue or about the Hetz report. It is also
significant that the Hetz report does not set forth in detail the
reasons for its recommendation that a "Rounded Estimate [sic]
Fair Market Value" for the Mark IV helmet that was the subject of
the report be $76,700. For example, the Hetz report offers no
explanation as to why the cost approach on which the report
purports to rely is the most appropriate method to use in deter-
mining the fair market value of the Mark IV helmet that was the
subject of that report. By way of further illustration, although
the Hetz report acknowledged that various factors, including the
"Sale of [a] similar Helmet", were to be taken into account,
apparently that factor was not considered, and the Hetz report
provides no explanation as to why it was ignored.
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