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date; and there is no evidence that the conditions of the
property changed in any material way between the date of
death and the date of the sale.
Even if we accept petitioner's contention that the
sale of 4.83 acres of the decedent's land to Hillsborough
County was an arm's-length sale by a willing buyer to a
willing seller, we are not certain that it is the best
evidence of the fair market value of the decedent's land.
We infer that petitioner may have had an incentive to reach
a speedy agreement for sale of the 4.83 acres with
Hillsborough County and may have been willing to sell the
property for less than its fair market value. We base that
inference on three factors: (1) It was difficult to sell
the decedent's property until Hillsborough County's plans
for the road project became more definite and known; (2)
the construction of the road project was anticipated to
increase the value of the surrounding areas, including
decedent's land; and (3) the County had the power to
condemn the property.
To reflect the foregoing and concessions,
Decision will be entered
under Rule 155.
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