- 68 -
For these reasons, Carneghi gave more weight to the income
capitalization approach, and less weight to the comparable sales
and replacement cost approaches. Carneghi’s final estimate of
the value of the retail/office portion of the Redwood City Fox
was $1,150,000.
c. Final Value Conclusion
Carneghi valued the theater component of the Redwood City
Fox at $2,000,000, and valued the retail/office component at
$1,150,000, for a final value estimate for the Redwood City Fox
of $3,150,000 as of December 31, 1986.
C. Respondent's Expert
Respondent determined in the notice of deficiency that the
value of the Redwood City Fox at the time of the gift was
$1,290,000. This valuation figure was based upon an appraisal
report prepared by Lawrence Mansbach (Mansbach).32 Mansbach is a
member of the Appraisal Institute and a certified General Real
Estate Appraiser in California. Mansbach is a principal in the
San Francisco-based firm of Mansbach Associates, Inc., and, in
the 1980's, worked for Carneghi, petitioner Crocker’s expert, as
a principal in Carneghi’s firm. Mansbach testified at trial as
respondent's expert.
32 Mansbach's associate, Jean Rote, assisted Mansbach with
the preparation of his appraisal report. The record does not
contain additional information regarding Ms. Rote's professional
qualifications.
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