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