- 85 - 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...)Page: Previous 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 Next
Last modified: May 25, 2011