Estate of Juanita F. Sirmans, Deceased Dan L. Sirmans, Executor - Page 22

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             6           1,300,000       89.500    --        14,525                   
             Thus, according to petitioner, the BAAS appraisal supports               
             the value reported on the decedent's estate tax return.                  
                  Petitioner also notes that the subject property had                 
             been informally shown to buyers by various brokers over the              
             course of approximately 1-1/2 years with an asking price                 
             of $25,000 per usable acre.  The property was then formally              
             listed with Wegman Realty, and that firm showed the                      
             property to approximately 200 persons over the course of                 
             another 1-1/2 years in an attempt to sell the property for               
             the same price.  Despite those efforts, no offer to                      
             purchase the property was received.  Petitioner notes that               
             respondent's value of $791,000 is $33,659 on a per-usable-               
             acre basis (23.5 usable acres).  If the decedent's property              
             was truly worth over $33,000 per usable acre, petitioner                 
             asks why no one offered to purchase the property at the                  
             listed price of $25,000 per usable acre.                                 
                  We note that, on the date of death, September 7, 1990,              
             it was generally known that Hillsborough County planned to               
             acquire a part of the decedent's property in connection                  
             with its plan to widen and realign Paglen Road.  However,                
             at that time, the precise configuration of the road project              
             was not known.  It stands to reason, as both Mr. Sirmans                 

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