Charles H. Browning, Jr., and Patricia L. Browning - Page 6

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          a price equal to only a portion (50 to 80 percent) of the maximum           
          expected fair market value of development rights.  In the case of           
          each acquisition of development rights pursuant to the Program,             
          before an offer was made by Howard County, the county obtained an           
          appraisal of the value of the subject property both encumbered              
          and unencumbered by the development restriction.  The price                 
          offered by the county was always less than the reduction in fair            
          market value indicated by the appraisal.                                    
          Market for Development Rights                                               
               During 1990, the only purchaser of development rights to               
          farmland in Howard County was the county, under the Program.                



          Petitioners’ Charitable Contribution Deductions                             
               With respect to petitioners’ participation in the Program,             
          Howard County obtained an appraisal by Edward A. Griffith of the            
          E.A. Griffith Real Estate Co., Towson, Maryland.  Mr. Griffith is           
          an experienced real estate appraiser.  Mr. Griffith conducted his           
          appraisal as of April 10, 1990, and concluded that the fair                 
          market value of the land was $771,600, the agricultural value of            
          the land was $173,052, and the value of the easement was                    
          $598,500.                                                                   








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