- 42 - concluded that his corrections had no effect on his ultimate conclusion that the value of CamVic's stock in May 1975 and April 1981 was $1.3 million or $9,496 per share and $1.8 million or $13,148 per share, respectively. Second, while Mr. Kimmel relied primarily upon the income approach in determining the value of CamVic's stock, he failed to provide an adequate explanation to justify his chosen expense estimates, which serve to reduce the valuation of a property under the income approach. When valuing Dina Terrace and Dina Tower, Mr. Kimmel estimated that expenses would be 55 and 47 percent of gross income for 1975 and 1981, respectively.31 It is well established that estimates and assumptions not supported by independent evidence are of little assistance and will not be accepted as probative of value. See, e.g., Rose v. Commissioner, 88 T.C. 386, 418 (1987), affd. 868 F.2d 851 (6th Cir. 1989); Chiu v. Commissioner, 84 T.C. 722, 730 (1985). Third, we note that Mr. Kimmel valued several properties below the value determined by Hamilton County, Ohio, for purposes of the county's property tax assessment. The parties have stipulated that Hamilton County computes the assessed value of real property by multiplying the county's estimate of market value by 35 percent. Using this formula, we have determined that Hamilton County 31In contrast, the computations regarding Dina Terrace and Dina Tower prepared by Mr. Hughes in 1975 show gross revenue of $360,217 and operating expenses of $144,087, indicating that expenses were only 40 percent of gross income. See supra p. 12.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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