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they prepared explaining how the rental was derived display a
conscientious, if not wholly convincing, effort to arrive at an
accurate appraisal. As the wide discrepancy between the
appraisals presented to the Court by the parties’ experts, Lady
and Cobb, illustrates, the making of an appraisal is not an exact
science. We are satisfied that Maschmeyer’s conduct on
petitioner’s behalf was consistent with ordinary business care
and prudence.
Indeed the $140,000 rental deduction claimed by petitioner
on its tax returns falls squarely within the range that Cobb, in
his expert opinion, considered reasonable ($871,000 x 16% =
$139,360; $871,000 x 18% = $156,780). Thus, petitioner’s
valuation was in fact consistent with that of a professional real
estate appraiser.
The accuracy-related penalty does not apply. To reflect the
foregoing,
Decision will be entered
under Rule 155.
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