Eugene D. Lanier, Inc. - Page 26

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          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 the                




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