- 18 -
percent. He arrived at a value for the Property of $612,800
(rounded).
After analyzing the values derived under each of the above
approaches, Lambert determined that the FMV of the Property was
$620,000.
For the reasons discussed below, we conclude that Lambert's
report is filled with shortcomings and errors which, in sum,
prove fatal to his conclusion regarding the FMV of the Property.
See Wolfsen Land & Cattle Co. v. Commissioner, 72 T.C. at 21 ("we
note that the reliability of this expert's opinion was severely
compromised by several errors in his calculations which surfaced
during the trial held herein.").
Lambert analyzed a total of 19 transactions to support his
valuation of the Property as of March 31, 1987, yet 15 of those
transactions had not transpired as of the valuation date. Among
the dispositions taking place after the sale of the Property,
Vacant Land Sale No. 5 occurred on September 30, 1988. Improved
Sale No. 3 did not take place until November 1988. (A sale of
the same property at a lower price, which Lambert did not
consider in his analysis, had occurred in November 1986.)
Improved Sale No. 2 did not take place until October 31, 1990.
Improved Sale No. 4 did not occur until February 1989. Moreover,
Lease Comparables 4 and 8 did not commence until September 1991.
Lease Comparable 5 was not in effect until May 6, 1993. Lease
Comparable 6 was not entered into until June 30, 1992.
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