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At $45,000 a lot, the value of the land before conveyance of the
easement to the county would be $675,000 on a dollar-a-lot basis,
which is Mr. Sapperstein’s opinion on the basis of the 15 lot
scenario. Therefore, we find that the before value of the land
on the conveyance date was $675,000.
4. Conclusion
Both of the parties' expert appraisers, Messrs. Lipman and
Sapperstein, rejected the purchase prices paid by Howard County
under the Program as evidence of the fair market value of any of
the development rights conveyed to the county, including the
easement conveyed by petitioners. We have considered the before
and after valuation opinions of the parties' experts and conclude
that the fair market value of the easement on the conveyance date
was $518,000.
V. Analysis of the Amount Realized from the Sale of the Easement
Respondent argues that, in addition to the cash payments
received and to be received by petitioners from Howard County,
petitioners received other valuable consideration: “The record
of this case makes clear that petitioners conveyed the
development rights easement to Howard County with the expectation
of receiving valuable benefits, including cash and anticipated
charitable contributions.” Respondent argues that the value of
tax deferral received from the installment sale of the easement
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