- 22 -
indicated in his report that, based on his experience as a
property manager, the property management, leasing, janitorial
and maintenance services performed by Ms. Friedeberg had an
average fair market value of $24,000 per year.
Mr. Chahin's report did not distinguish between the amount
of services provided for each of the different properties based
on the number of rental units in each building or otherwise. Mr.
Chahin's report did not distinguish a difference in value over
the course of 18 years, notwithstanding the fact that more units
were acquired over time. The report simply states that the fees
charged in general have remained "relatively constant in
California since the early 1980's." Also, it is unclear from Mr.
Chahin's report which properties the valuation is based on. Mr.
Chahin's report does not appear to address the Laidley, South
Fitch, or Acadia properties. Because the value assigned by Mr.
Chahin is arrived at in a conclusory fashion, without taking into
account the changes in the amount of services or the value of the
services over time, Mr. Chahin's report does not persuade us that
the value of Ms. Friedeberg's services was $24,000 per year, and
we are not bound by it. Parker v. Commissioner, 86 T.C. 547, 561
(1986).
Even assuming that we accepted a value of $24,000 per year,
petitioner has not offered evidence as to which among the various
rental properties the value should be allocated or in what
Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: May 25, 2011