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death. Petitioner contends that respondent is transfixed on the
concept of location and that she has failed to factor into her
analysis the many characteristics of parcel A which detract from
its utility. Petitioner’s argument suffers from at least one
significant flaw. Just as respondent has placed considerable
reliance on the location of parcel A, contending that such
location evinces its commercial qualities, petitioner has relied
to an equal extent in arguing that parcel A is located in a
residential area. We do not regard either argument as
determinative.
We are convinced that the highest and best use of parcel A
as of the date of decedent's death was commercial in nature;
such use was reasonable and probable. See Symington v.
Commissioner, 87 T.C. at 897. Considering the entire record,
with particular emphasis on the appraisal reports prepared by
Tidwell, Hearn, Young and Dilmore, we find that the conclusions
reached by both Dilmore and Young relating to the highest and
best use of parcel A were realistic and objective under the
circumstances of this case. See Stanley Works & Subs. v.
Commissioner, 87 T.C. at 400.
b. Parcel B
The parties are in agreement that the highest and best use
of parcel B, as of the valuation date, was commercial in nature.
Each of the four appraisers, Tidwell, Hearn, Young, and Dilmore,
concluded that a rezoning of parcel B from residential to
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