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the gift is complete); see also sec. 25.7520-1(b)(1)(ii), Gift
Tax Regs.
With respect to the value of the four parcels decedent
transferred, petitioner contends that the land had a fair market
value of $1,865,500, whereas respondent contends the land's fair
market value was $1,945,925. No expert testimony was offered by
the parties. Respondent relies heavily upon the appraisal report
that petitioner obtained and provided to the estate tax examiner.
In that appraisal report, the real estate appraiser concluded
that the fair market value of decedent's land was $1,945,925, as
of August 29, 1989. Jerry, however, testified that the land was
worth only $1,865,500, as two of the parcels were worth somewhat
less than the real estate appraiser had estimated. Jerry
explained that the appraiser had failed to take into account (1)
the significant portions of sand on these two parcels and (2) the
thinner topsoil layers making them less suitable for certain
crops. We found Jerry's testimony to be credible, as he was
familiar with decedent's land, had considerable experience in
farming, and was knowledgeable about farmland prices in the
Wellton, Arizona, area. In addition, we would note that the
appraisal report, though prepared by a qualified real estate
appraiser, was expressly stated to be only a "preliminary
valuation" of the four parcels. We hold that decedent's land had
a fair market value of $1,865,500, as of August 29, 1989.
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