Estate of Willie C. Lloyd, Deceased, Iva Nell Holman, Executrix - Page 17

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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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