Estate of Juanita F. Sirmans, Deceased Dan L. Sirmans, Executor - Page 16

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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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