- 17 - 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 thePage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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