Allen M. Glick - Page 13

                                       - 13 -                                         
          expert's ultimate conclusion if unsupported by the record.                  
          Owensby & Kritikos, Inc. v. Commissioner, 819 F.2d 1315, 1331               
          (5th Cir. 1987), affg. T.C. Memo. 1985-267.                                 

          Valuation Methodology                                                       

               The parties presented two alternative methods of valuing the           
          Property:  (1) The comparable sales method (CSM); and (2) the               
          subdivision development method (SDM).  The CSM involves gathering           
          information on sales of property similar to the subject property,           
          then making adjustments for various differences between the                 
          "comparables" and the property being appraised.  Estate of                  
          Spruill v. Commissioner, 88 T.C. 1197, 1229 n.24 (1987).                    
               The SDM determines the value of undeveloped land by treating           
          the land as if it were subdivided, developed, and sold.  From the           
          proceeds of sale, development costs are then subtracted.                    
          Finally, the expected net proceeds are discounted over the                  
          estimated period required for market absorption of the developed            
          lots in order to determine the amount a developer would pay for             
          the undeveloped property; i.e., the property's fair market value.           
          Branch v. Commissioner, T.C. Memo. 1987-321.                                
               In his report, Mr. Avery used both methods to value the                
          Property, relying primarily on the SDM.  Although he used the CSM           
          for support, Mr. Avery admitted that "none of the parcels                   
          analyzed had the locational or physical attributes of the subject           
          property."  As a result of these differences, Mr. Avery made                




Page:  Previous  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  Next

Last modified: May 25, 2011