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in the use of any portion of such an opinion, Parker v.
Commissioner, 86 T.C. 547, 562 (1986).
1. Appraisal Reports
All four expert appraisers used the comparable sales method
in arriving at values for the property. The comparable sales
method functions by (1) locating properties as physically similar
as possible to the subject property which (2) have been sold on
the open market in noncollusive, nonforced sales for cash or cash
equivalent, within (3) a reasonable time of the date for which a
value of the subject property is desired. Once these properties
are located, those features of the subject property that are most
pertinent to its value are compared to those same features on the
comparable properties. Since no two sales and no two properties
can be identical, the value of those features of the comparable
properties which are relevant to the value of the subject
property are adjusted until they are of a quality equivalent to
those of the subject property. This Court has found the
comparable sales valuation method to be a reasonable one and has
used it in the past. See Frazee v. Commissioner, 98 T.C. 554
(1992); Wolfsen Land & Cattle Co. v. Commissioner, 72 T.C. 1, 19
(1979).
The parties have gone to great lengths in their attempts to
discredit the validity and usefulness of the appraisal reports
relied upon by their opponents. Petitioner, in particular,
adamantly maintains that the Dilmore report is devoid of utility
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