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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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