- 48 - each property's market value. The same is true with respect to the seven facts ascertained by Dr. Perry on the condition of the real estate market in Genesee County. The appraisers knew about each of these facts at the time of their appraisals, and we find nothing in the record to persuade us that they did not give each of these facts proper regard in arriving at their values. Discounting the appraisers' values to reflect the economic condition in Genesee County on the applicable valuation date, as the estate asks us to do, would be to double count this effect. See Estate of Gilford v. Commissioner, 88 T.C. 38, 58 n.25 (1987). We decline to do so.15 Nor are we satisfied with the testimony of Mr. Shanker. To be sure, he is biased. He works professionally valuing assets for his clients, and we would be advancing his interests as well as the interests of his clients were we to adopt blindly his opinion, which is unsupported by the record, on the presence of an across-the-board 20-percent market absorption discount. We decline to accept the opinion of a man whose only appearance in this case seems to be as a spokesman for the interests of his clients and the estate. Laureys v. Commissioner, 92 T.C. 101, 129 (1989). The Court informed the parties at the start of Mr. Shanker's testimony that we had 15 The estate also argues that market absorption discounts are warranted because the apartment complexes had a high vacancy rate and the rental rates were not keeping up with inflation. We reject these arguments for the same reason as above; namely, that the appraisers took these factors into consideration in arriving at their values.Page: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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