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The record is anything but conclusive with regard to the
effect that a lack of immediate sewer connections has on the
value of parcel B. The testimony of several witnesses supports
petitioner’s argument, but evidence also exists in support of the
contention advanced by respondent.
We agree with both parties that the highest and best use of
parcel B was commercial in nature at the time of decedent's
death. Such use was both realistic and objective under the
circumstances. See Stanley Works & Subs. v. Commissioner, 87
T.C. at 400. Additionally, we are generally inclined to agree
with respondent with regard to the extent that the several
characteristics discussed above influence the commercial utility
of parcel B. While we recognize that petitioner’s argument on
that score has some merit, much of petitioner’s concern is
exaggerated.
4. Evidentiary Value of the Offers and Options
On brief, petitioner advances a rather lengthy argument with
respect to how this Court should view respondent's introduction
into evidence of several offers to buy and option contracts to
purchase portions of the trust property. We find this argument
to be without merit. It is clear that as a general rule,
unaccepted offers have no more than limited probative weight in
estimating value. Sharp v. United States, 191 U.S. 341 (1903);
Jayson v. United States, 294 F.2d 808 (5th Cir. 1961). Indeed,
this general rule has been held applicable to both offers and
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