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2. Petitioners' Experts
a. Moses
Moses appraised the Putnam County and Clay County land. He
used a combined income and comparable sales (market data)
approach. He inspected the Putnam County property in 1984 to
estimate its volume of timber and all of the properties in
question in 1992 to appraise them for estate tax purposes. He
conducted timber cruises in both years to estimate the amount and
value of timber on the property. He considered 15 sales of what
he said was similar rural land in North Florida to estimate the
value of the property. Moses concluded that the highest and best
use of both properties was agricultural.
Moses did not find any actual sales of undivided or
fractional interests in comparable real property. He concluded
that fractional interests in such property are not marketable.
b. Wiggins
To estimate the fair market value of the three fractional
property interests, Wiggins applied a 44-percent discount to one-
half of the value of the fee simple estimated by Moses. Wiggins
computed a 44-percent discount through seriatim application of
discounts of 30 percent for lack of control and 20 percent for
lack of marketability. He estimated that partition costs would
be $164,400 for the Putnam County property, $172,500 for the Clay
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