- 32 -
a comparable lease, as it in part reflected the sale of the
automobile dealership to Harvey. Nor do we consider the $10,000-
per-month lease between the Laniers and the Corporation to be a
comparable lease, as it did not represent an arm's-length
transaction. See Ingle Coal Corp. v. Commissioner, 174 F.2d 569,
571 (7th Cir. 1949), affg. 10 T.C. 1199 (1948). Our estimated
lease rate for the Property incorporates a positive adjustment
for location, corner influence, and physical condition, and a
slightly greater downward adjustment for size and market
condition. This yields a gross annual income of $63,388. No
expenses are subtracted from that amount, as we agree with
Parker's and Aguilar's assumption of a net lease for the
Property. Moreover, we think that a capitalization rate of 12
percent is reasonable. It falls squarely within the range of
11.83 to 12.45 percent determined by the experts. This produces
a final estimated FMV for the Property of $528,233.
While the record contains no reference to the exact dollar
figure of FMV determined by the Court, it is well settled that
Valuation * * * is necessarily an approximation * * *.
It is not necessary that the value arrived at by the
trial court be a figure as to which there is specific
testimony, if it is within the range of figures that
may properly be deduced from the evidence.
Anderson v. Commissioner, 250 F.2d 242, 249 (5th Cir. 1957),
affg. in part and remanding for computational matters T.C. Memo.
1956-178; see McGuire v. Commissioner, 44 T.C. 801, 810-811
(1965). That is the situation here.
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