Eugene D. Lanier, Inc. - Page 24

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               Parker relied on the replacement-cost, market-data, and                
          capitalization-of-earnings approaches in appraising the value of            
          the Property at $420,000 as of March 31, 1987.  In appraising the           
          Property at $490,000, Aguilar used the replacement-cost and                 
          capitalization-of-earnings approaches, but opted against using              
          the market-data approach.  Petitioners maintain that their                  
          experts have established a reasonable range of values for the               
          Property and that the purchase price of $425,000 falls within               
          that range.                                                                 
               Parker's report was prepared in August 1994.  For the                  
          replacement-cost approach, Parker estimated the value of the                
          underlying land to be $125,000 (rounded), using 6 vacant land               
          sales as comparables ($1.40 per square foot times 89,380 square             
          feet).  He then estimated the 1987 reproduction cost new of the             
          buildings and other improvements at $610,616.  Accrued                      
          depreciation (incurable physical deterioration and external                 
          obsolescence) was estimated at $303,673, for an estimated                   
          depreciated cost of the improvements of $306,943.  Thus, his                
          estimate of value under this approach was $432,000 (rounded).               
               For the market-data approach, Parker analyzed 3 sales of               
          automobile agencies in Lafayette.  The sales were adjusted to               
          account for physical characteristics.  He estimated the value to            
          be $420,000 under this approach.                                            
               Finally, using 4 lease comparables (including leases of                
          Improved Sales Nos. 1, 2, and 3 entered into after the purchases            




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