- 23 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23
Last modified: May 25, 2011