Pope & Talbot, Inc., & Subsidiaries - Page 17

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          the owner would have paid if the property had been subject to the           
          ad valorem tax rate for the preceding 10 years.                             
               In the present case, we are trying to determine what a                 
          hypothetical buyer would pay for an entire tree farm, not just              
          the delivered logs.  Thus, we think that a buyer would consider             
          such costs as slash burning and reforestation, because those are            
          costs associated with operating a tree farm.  Petitioner has not            
          persuaded us, however, that a hypothetical buyer would consider             
          scaling costs, as those costs are normally incurred by the                  
          purchaser of the timber, not the owner of the tree farm.                    
               Respondent also argues that petitioner’s expert has                    
          overstated the contract logging costs.  The parties agree that              
          petitioner’s actual costs for 1985 are relevant in determining              
          the reasonableness of any cost estimate.  Petitioner claims that            
          its actual costs were approximately $161/MBF in 1985, which                 
          establishes the reasonableness of Mr. Granvall’s estimate of                
          $154/MBF.  However, petitioner's actual cost records include a              
          substantial amount for general administrative costs that                    
          significantly exceeds the amount of administrative costs that               
          even petitioner's expert includes in costs.  Respondent, on the             
          other hand, claims that petitioner’s actual costs, using only the           
          cost items listed by petitioner's expert, were approximately                
          $107/MBF, which confirms the reasonableness of Mr. Prochnau’s               
          estimate of $106.48/MBF.  However, this is partially attributable           
          to differences in the way the cost elements are described in the            




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