Estate of Albert Fratini, Deceased, Marion Friedeberg, Personal Representative - Page 22

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          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           
               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                  

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