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57 T.C. 650, 659 n.8 (1972), affd. 510 F.2d 479 (2d Cir. 1975)
(Provided they are not too far removed from the * * *
[valuation] date, sales before and after such date may be used to
corroborate the ultimate determination of * * * [FMV].) While
comparables entered into subsequent to the valuation date can be
used, adjustments need to be taken into account to reflect market
changes between the comparable's date of sale and the valuation
date. In this case, Lambert did not make any time adjustments.
Under the replacement-cost approach, Vacant Land Sale No. 5 was
used, but Lambert did not make any market condition adjustment to
reflect the 18 months that transpired after the valuation date.
Under the market-data approach, Improved Sales No. 2, 3, and 4
were used, but again Lambert did not make any adjustment for
market condition and time. Lambert merely concluded that no
clear evidence existed to make an adjustment. With the
capitalization-of-earnings approach, Lease Comparables No. 4, 5,
6, and 8 were used. In making his determination, Lambert used
the current rental rates, which covered the following periods:
September 1991 to September 1996 for Lease Comparable No. 4; May
1, 1993 to April 30, 1998 for Lease Comparable No. 5; January 1,
1993 to December 31, 1997 for Lease Comparable No. 6; and
September 1, 1991 (annual lease) for Lease Comparable No. 8. At
2(...continued)
mentioned. For example, Vacant Land Sale No. 5 is a reliable
comparable because it is located in the Johnston corridor and it
is similar in size and shape to the Property.
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