- 26 - market change and time under the market-data approach was inappropriate. Furthermore, Parker viewed Land Sale No. 2 as an arm's- length transaction even though it was actually a sale of an undivided half-interest in property between a mother and daughter. Transactions between family members are not arm's- length transactions and are subject to special scrutiny. Harwood v. Commissioner, 82 T.C. 239, 258 (1984), affd. without published opinion 786 F.2d 1174 (9th Cir. 1986); Estate of Whitt v. Commissioner, T.C. Memo. 1983-262, affd. 751 F.2d 1548 (11th Cir. 1985). Respondent's expert Lambert stated that, as no money was actually transferred between the two parties, it should not be viewed as a comparable sale. We find Lambert's testimony on this point credible, and we agree with his conclusion. Finally, Parker deducted $450,000--an amount equal to half of the purchase price--from Land Sale No. 1 for superior market conditions with no explanation as to how he arrived at a deduction of such magnitude. Petitioner's second expert, Aguilar, prepared his report in October 1991. For the replacement-cost approach, Aguilar used 6 land sales as comparables, which he then adjusted for size, date of sale, and corner influence. Aguilar valued the underlying land at $268,167, or $3 per square foot. Aguilar looked only at land sale comparables as of March 31, 1987; he did not look at sales occurring after that date. Aguilar then estimated thePage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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