Eugene D. Lanier, Inc. - Page 18

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          percent.  He arrived at a value for the Property of $612,800                
               After analyzing the values derived under each of the above             
          approaches, Lambert determined that the FMV of the Property was             
               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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