- 24 - We decline to address in any significant detail any of the further attempts by either party to discredit the appraisal reports presented by the party’s opponent. We recognize and accept that Tidwell, Hearn, Young, and Dilmore are each experts in their profession of real estate appraising, but we further recognize that reasonable experts specializing in the same profession often disagree. It is to such disagreement that we attribute any differences in substance, style, and quality among the appraisal reports presented by each party. 2. Property Valuation Property includable in a decedent's gross estate is generally reported at its fair market value on the date of the decedent's death. Sec. 2031(a);1 sec. 20.2031-1(b), Estate Tax Regs. Fair market value is the "price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts." United States v. Cartwright, 411 U.S. 546, 551 (1973); Estate of Bright v. United States, 658 F.2d 999, 1005-1006 (5th Cir. 1981); Frazee v. Commissioner, supra at 562; sec. 20.2031-1(b), Estate Tax Regs. The determination of value is to be made as of the valuation date, and knowledge of unforeseeable future events that may have 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at the date of the decedent’s death, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011