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Ms. Auker-Cooper, who during the life of the decedent assisted him in
most transactions concerning the subject property, never pursued any
of these inquiries. Ms. Auker-Cooper never attempted, or intended,
to sell (or cause an entity to sell) any of the subject property
following the decedent's death.
The apartment complexes comprised in the aggregate
approximately: (1) 19 percent of the total number of comparable
complexes in Genesee County, (2) 20 percent of the total number of
comparable units in Genesee County, and (3) 23 percent of the total
assessed value of comparable complexes in Genesee County. Sales of
real property in Genesee County totaled $224,118,947, $233,473,144,
$254,681,378, $334,900,262, $416,229,204, $467,763,158, and
$484,248,800 in 1990 through 1996, respectively. Of the total sales
in 1992, which were 4,015 in number, $7,725,174 was attributable to
vacant land (321 sales), $2,168,270 to income-producing property
(42 sales), and $2,706,475 to commercial property (39 sales).
Most of the other sales during 1992 were attributable to the sale of
owner-occupied homes.
OPINION
Disputes over valuation fill our dockets, and for good reason.
We approximate that 243 sections of the Code require fair market
value estimates in order to assess tax liability, and that 15 million
tax returns are filed each year on which taxpayers report an event
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