Estate of Willie C. Lloyd, Deceased, Iva Nell Holman, Executrix - Page 16

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          were also adjusted to account for the date upon which the                   
          comparable sale occurred and the physical characteristics of the            
          land involved.                                                              
               The results of Young's analysis can be summarized as                   
          follows:                                                                    
          FMV of Decedent’s                                                           
          Parcel    FMV per Acre    FMV of Parcel      50% Interest                   
          A         $100,000       $6,800,000          $3,400,000                     
          B         180,000        1,800,000           900,000                        

          6.   Petitioner’s Appraisal Reports                                         
               Petitioner bases its argument on the results of appraisal              
          reports prepared by two experts, Hearn and Lonnie Tidwell                   
          (Tidwell).  Like Dilmore and Young, Hearn and Tidwell are                   
          professional appraisers with respectable credentials.  The Hearn            
          report provided the basis for the amended return, while the                 
          Tidwell report was prepared approximately 2 years thereafter.               
               a.   Hearn's Appraisal                                                 
               Hearn provided its valuation report of parcels A and B to              
          Dudley on September 28, 1988.  Hearn conducted an individual                
          comparable sales analysis with respect to both parcels of trust             
          property.  Both individual analyses involved the use of five                
          comparable sales.  Neither analysis involved the use of a                   
          comparable sale used in the other analysis.  Hearn concluded that           
          the highest and best use of parcel A at the time of decedent's              
          death was residential in nature.  Each comparable sale Hearn used           





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