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on the BAAS appraisal dated April 18, 1990. That appraisal
was requested by the decedent's son, Mr. Dan Sirmans, and,
respondent argues, it is the only appraisal which considers
all 56.5 acres of the decedent's land and is the best
evidence of the land's value on September 7, 1990, the date
of the decedent's death, 81 days later.
The value of the subject property reported for estate
tax purposes, $509,529, is based on the Fishback appraisal
of the parcel designated folio 3143 that was made at the
request of Hillsborough County in connection with its
purchase of 4.83 acres of that parcel for a road right-of-
way. Petitioner contends that the reported value of the
subject property is shown to be the correct value by
"the great weight of the valuation evidence" in this case,
consisting of the Hunt appraisal in 1984, the Hillsborough
County real estate tax assessments for the years 1988,
1989, and 1990, the comparable sales listed in the BAAS
appraisal in 1990, the Fishback appraisal in 1991, the
sale of 4.83 acres of folio 3143 to Hillsborough County,
the opinion of Mr. Joseph Wegman of Wegman Realty, and
Mr. Sirmans' own experiences in trying to sell the subject
property for the decedent. Petitioner also contends that
the BAAS appraisal, on which respondent's determination is
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