- 11 -
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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