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August 4, 1993, was $575,000. Where an expert's report is based
upon an incorrect assumption (such as the valuation date in this
case), the Court may still use it to construct reliable estimates
of value by adjusting for the faulty assumption. Anselmo v.
Commissioner, 80 T.C. 872, 884-885 (1983), affd. 757 F.2d 1208
(11th Cir. 1985). In making the valuation, petitioners' expert
relied on comparable sales of three properties. The expert
report provides the following additional information:
1. Single family homes or condominium units with a
waterfront view will command the highest prices. Although bay
view sites are desirable in the market place, bay view sites are
considered to be an inferior view to the open gulf view of 300
Gulf Boulevard.
2. 300 Gulf Boulevard and comparables No. 2 and No. 3 are
located directly on the Gulf of Mexico in the same subdivision.
Since Comparable No. 1 is located on the bay in a neighboring
subdivision within the area, a large adjustment for the inferior
view was warranted.
3. The expert rated 300 Gulf Boulevard as being in above-
average condition because the interior of the home had been
renovated and modernized. The kitchen had been remodeled and had
new cabinets. The exterior of the home needed painting, and some
of the gutters were rotted. There were no functional or physical
inadequacies noted during the inspection.
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