John T. Talkington and Margaret K. Talkington - Page 25

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          square feet) on December 15, 1992,9 to be $380,000 based on a               
          value of $0.75 per square foot.  Mr. Cantrell compared the 11.656           
          acres to eight other land comparables that ranged in size from              
          25,264 square feet to 1,408,948 square feet, that were sold or              
          were being offered for sale between January of 1986 and December            
          of 1992, and that had sale prices or offers between $0.12 and               
          $1.10 per square foot.  After adjusting his comparables, he                 
          determined that the comparable properties had a mean price per              
          square foot of $0.57.                                                       
               Mr. Cantrell did not adjust the comparables for changes in             
          market conditions (time).  Mr. Cantrell's report states that                
          there was a relatively slow market for land in the neighborhood             
          in which the Litton property was located.  According to Mr.                 
          Cantrell, this supported his decision not to adjust the                     
          comparables for changes in market conditions.  Mr. Cantrell                 
          adjusted the comparables for location, size, and "other".10                 
          Almost all of Mr. Cantrell's adjustments were positive, although            
          he did make negative adjustments to three comparables for size              
          and to one for "other".                                                     
               We believe Mr. Cantrell's conclusions to be unrealistic and            
          unreliable.  In his analysis, virtually every property was                  
          inferior except the highest price sale ($1.10 per square foot)--a           
          property that was considerably smaller in size and located in a             

               9  Petitioners donated the gifted Litton property on Dec.              
          17, 1992, not on Dec. 15, 1992.                                             
               10  It is unclear what "other" adjustment was for.                     


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