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Theater Retail/Office Total Value
Ingram/Ewing $3,850,000 $1,448,000 $5,300,000
Mitten/Reynolds 3,500,000 1,100,000 4,600,000
Carneghi 2,000,000 1,150,000 3,150,000
Mansbach 660,000 631,000 1,290,000
Based upon their respective expert's report and testimony,
the parties take the following positions regarding the fair
market value of the Redwood City Fox:38
Theater Retail/Office Total Value
Jacobs: $3,850,000 to $1,150,000 to $5,000,000 to
3,500,000 1,100,000 4,600,000
Crocker: 2,000,000 1,000,000 3,000,000
Respondent: 660,000 631,000 1,290,000
In arriving at their estimated fair market values, the
experts in these cases relied upon one or more of the three
commonly recognized methods of valuing real property and other
assets: (1) The replacement cost approach;39 (2) the comparable
sales approach;40 and (3) the income capitalization approach.41
38 Respondent requests that we sustain the value determined
by Mansbach and find that the fair market value of the Redwood
City Fox was no greater than $1,290,000. Thus, while respondent
does not request separate findings of fact with respect to the
theater and retail/office components of the property, we assume
the values for the separate components estimated by Mansbach to
be reflective of respondent's position.
39 See Marine v. Commissioner, 92 T.C. 958, 983 (1989),
affd. without published opinion 921 F.2d 280 (9th Cir. 1991).
For purposes of this opinion, the terms "replacement" and
"reproduction", when used to describe cost, are synonymous.
40 See Estate of Spruill v. Commissioner, 88 T.C. 1197, 1229
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