- 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.
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