Eugene D. Lanier, Inc. - Page 20

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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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