Cameron W. Bommer Revocable Trust, Ronald Bommer, Trustee - Page 42

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            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.                            




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