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adjustments will be made. Estate of Gilford v. Commissioner,
supra. We note, however, that counsel for respondent did not see
fit to cross-examine petitioners' expert during the trial of this
case.
Petitioners' expert used the comparable sales method in
arriving at a value for the property. The "comparable sales"
method functions by: (1) Locating properties as physically
similar as possible to the subject property which (2) have been
sold on the open market in noncollusive, nonforced sales for cash
or cash equivalent, within (3) a reasonable time of the date for
which a value of the subject property is desired. Once these
properties are located, those features of the subject property
which are most pertinent to its value are compared to those same
features on the comparable properties. Since no two sales and no
two properties can be identical, the values of those features of
the comparable properties which are relevant to the value of the
subject property are adjusted until they are equivalent to those
of the subject property. This Court has found the comparable
sales valuation method to be a reasonable one and has used it in
the past. Wolfsen Land & Cattle Co. v. Commissioner, 72 T.C. 1,
19 (1979).
Petitioners' Expert Report
Petitioners' expert appraised the subject property in 1994.
In his report, he concluded that the value of the property as of
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