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We believe their adjustment for physical condition was too
high in view of the location of the San Jose Fox. Similarly,
Mitten/Reynolds concluded that the sales of the San Jose Fox and
the Stanford, whose purchase prices equated to $82.50 per square
foot and $71.71 per square foot, respectively, indicated a fair
market value for the Redwood City Fox of $135 per square foot.
As with Ingram/Ewing, we are not persuaded that such large upward
adjustments to the purchase prices of the San Jose Fox and the
Stanford are warranted. We think the location of the Redwood
City Fox was inferior to the locations of the comparable
properties. Consequently, we find that Ingram/Ewing and
Mitten/Reynolds approaches resulted in an inflated fair market
value.
After examination of the record, we find Crocker's expert,
Carneghi, to be more persuasive than the other experts. As
mentioned above, where we find the evidence of valuation by one
of the parties sufficiently more convincing than that of the
other party, we may accept the opinion of the expert in its
entirety. Buffalo Tool & Die Mfg. Co. v. Commissioner, 74 T.C.
at 452. In these cases, with respect to the theater component of
the property, we accept Carneghi's opinion in its entirety.
Carneghi considered the sales of the San Jose Fox, the
Stanford, and the Circle Star to be comparable to the Redwood
City Fox. Carneghi also considered the purchase of the Redwood
City Fox by Jacobs in May 1981. Due to Jacobs’ renovation of the
Redwood City Fox, as well as what Carneghi termed “booming” real
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