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Commissioner, 87 T.C. 389, 400 (1986). The highest and best use
of property is the realistic, objective potential use to which
the property can be put. The determination of fair market value
is not dependent upon whether the property is actually being put
to its highest and best use. Here, the parties agree that the
highest and best use for the Property is as an exclusive
residential subdivision.
Petitioner's Experts
In this case, the parties have relied extensively on the
testimony of expert witnesses to support their respective views
on the fair market value. Petitioner has submitted the reports
of three appraisers: (1) Ronald B. Handverger, (2) Martin C.
Segel, and (3) Kenneth G. Dallamora. Each of these experts
stated that the fair market value of the Property was in excess
of $12 million in October 1986.
Mr. Handverger has been actively engaged in the real estate
profession for over 20 years. He is a certified general real
estate appraiser in the Commonwealth and the owner of Handverger
& Associates, which is an appraisal consulting firm in the town
of Framingham. Mr. Handverger prepared the original appraisal
report on the Property, which petitioner used in determining the
value of the Property for his 1986 Federal income tax return.
Mr. Handverger also prepared a revised report prior to trial.
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