Jane Crocker, F.K.A. Jane C. Jacobs, et al. - Page 95

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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           
                                                             (continued...)           


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