- 22 -
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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