Eugene D. Lanier, Inc. - Page 21

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          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 conclude              






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