Neal T. Baker Enterprises, Inc. - Page 24

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          of $490,560.  Petitioner compares these estimates to the off-site           
          costs incurred in regard to the 14 lots of approximately $5,000             
          per lot.                                                                    
               In regard to the off-site improvements, respondent submitted           
          an expert report, prepared by Donald Lohr, which estimated the              
          off-site improvement costs for the Beaumont Property.  Mr. Lohr             
          estimated off-site improvements for the 14 lots in Tract No.                
          10018-1 to be $5,821.82 per lot.  Using the 1987 cost estimate,             
          to which he then added costs of waterlines and appurtenances plus           
          costs for miscellaneous items, Mr. Lohr initially determined the            
          off-site cost in 1987 was $10,767.74 per lot for the Exchange               
          Property (the 1989 cost would be $11,198.45).  In light of                  
          information available after filing his report (the 1988 cost                
          estimate), Mr. Lohr determined that the off-site costs were                 
          slightly over $12,000 per lot for the Exchange Property.                    
          Mr. Lohr stated that these costs associated with Tract No. 10018-           
          1 and Tract No. 22332 were not prohibitive.  According to Mr.               
          Lohr, "[t]he [costs] to develop Tract No. 10018-1 were below the            
          average cost to develop single-family lots at that time and the             
          [costs] to develop Tract No. 22332 were no more than average" in            
          relation to those prevailing in 1989.                                       
               According to Mr. Kanengiser of Meadowlark Homes, the                   
          off-site costs incurred by Meadowlark Homes in developing the               
          Exchange Property were not cost prohibitive.  Meadowlark Homes              





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