John T. Talkington and Margaret K. Talkington - Page 11

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          See also Buffalo Tool & Die Manufacturing Co. v. Commissioner, 74           
          T.C. 441, 451-452 (1980).  We are now faced with the task of                
          rationally resolving differences in the opinions and often                  
          subjective analyses of two qualified experts.  In reaching our              
          ultimate conclusions as to the valuation of the parcels here in             
          issue, we must, because of the possibility of an appeal, set out            
          a trail for the appellate court to follow.  See Symington v.                
          Commissioner, supra at 904.  We are constrained to admit,                   
          however, that by necessity our conclusions are to some extent               
          based upon Solomon-like pronouncements.  We remain convinced, as            
          we have repeatedly stated, that valuation cases should be                   
          disposed of by the parties by way of settlement or other                    
          procedures short of court proceedings.  See, e.g., Symington v.             
          Commissioner, supra at 904-905.                                             
          I.   The Experts                                                            
               Petitioners' expert was Tommy Cantrell, MAI, RM.  Mr.                  
          Cantrell has been an appraiser of property for approximately 28             
          years.  On December 31, 1992, on behalf of petitioners, Mr.                 
          Cantrell appraised the gifted Litton property.  On January 7,               
          1993, on behalf of Mr. Sessions, Mr. Cantrell appraised the Bates           
          Center.                                                                     
               Respondent's expert was Dr. Jack Friedman, Ph.D., MAI, CRE,            
          ASA, C.P.A., and a Texas State Certified General Appraiser.  In             







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