Estate of Willie C. Lloyd, Deceased, Iva Nell Holman, Executrix - Page 40

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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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