- 21 - trial, Lambert admitted he should have used an earlier lease for Lease Comparable No. 4 in effect on March 31, 1987 (which changed the rental rate from $5.24 in 1991 to $3.38 in 1987). We think that the use of these comparables without relevant adjustments for market conditions and time was inappropriate in light of the "precipitous" decline in real estate values in Lafayette in late 1986 and the fact that the recession in Lafayette was severest during 1985 through 1987, with the lowest point occurring during the first quarter of 1987 when the transfer of the Property occurred. Because the validity of an expert's determination depends upon on the comparables selected and the adjustments, Wolfsen Land & Cattle Co. v. Commissioner, 72 T.C. at 19-20, we discount Lambert's determination of the Property's FMV. Moreover, 10 of the transactions used by Lambert in his appraisal report took place outside of the Lafayette market. Of those transactions, Lease Comparables 1 and 2 were located in Sulphur, Louisiana. Lease Comparable 3 was in Lake Charles, Louisiana. Lease Comparables 5, 6, 8, and 9 were in Baton Rouge, Louisiana. Lease Comparable 7 was in Gonzales, Louisiana. Lambert does not provide any information in his report that the lease rates in these various markets were similar to those in Lafayette; he himself stated that the Lafayette market suffered the most in Louisiana due to the recession. Thus, we concludePage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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