- 28 - 14(h)(3)(i), Income Tax Regs., available to use as a “meaningful or valid” comparison to the sale of the easement. E. Before and After Valuation 1. Introduction The market for sales of development rights to the county under the Program was not an uninhibited market, but was a market characterized by sellers intending to make gifts to the county by way of bargain sales; therefore, petitioners are entitled to show the fair market value of the easement by evidence of the fair market value of the land before and after the conveyance of the easement. Sec. 1.170A-14(h)(3)(i), Income Tax Regs. (third substantive sentence). We shall now consider the expert testimony presented by both parties with respect to those values. 2. After Value The parties' expert appraisers, Messrs. Sapperstein (for petitioners) and Lipman (for respondent), agree that the highest and best use of the land after the conveyance of the easement to the county is as a farm. Both experts value the land subject to the easement at $157,000. Therefore, we find that the after value of the land subject to the easement on the conveyance date was $157,000. 3. Before Value Messrs. Sapperstein and Lipman also agree that the highest and best use of the land before the conveyance of the easement toPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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