- 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.
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