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with respect to parcel A had a residential zoning classification.
With respect to parcel B, Hearn concluded that its highest and
best use was commercial in nature. The properties used by Hearn
with respect to parcel B had office and commercial zoning
classifications. All 10 comparable property sales used by Hearn
involved the sale of real estate located in the general vicinity
of the trust property. Hearn's conclusions as to the values of
parcels A and B were made subject to each parcel’s obtaining
access to a sanitary sewer system. Hearn's conclusion with
respect to parcel B was further contingent on that parcel’s being
accessible to development and able to support improvements.
Hearn's appraisal involved making numerous adjustments to the
comparable property sales. Adjustments were made for date of
sale, location, market, utilities, and size. The results of
Hearn's analysis can be summarized as follows:
FMV of Decedent’s
Parcel FMV per Acre FMV of Parcel 50% Interest
A $20,000 $1,300,000 $650,000
B 75,000 750,000 375,500
These results were used in the completion of the amended return.
b. Tidwell's Appraisal
In October 1990, 2 years after the amended return was filed
by Holman and Spraggins, Tidwell responded to an earlier request
by Dudley to conduct an appraisal of parcels A and B. Tidwell
presented an extensive analysis of both parcels. Consistent with
standard appraisal techniques, Tidwell conducted a highest and
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