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He estimated that a fee simple interest in the Putnam County
property was worth $1,598,100 ($700 per acre) in 1980. Elmore
used sales that he said were comparable to estimate that a fee
simple interest in the Clay County property was worth $2,083,500
($900 per acre) in 1983. He divided both of these amounts in
half because decedent gave petitioner an undivided one-half
interest in the two properties. Elmore applied no discount to
take into account the fact that petitioner received undivided
interests in the properties.
4. Value of a Fee Simple Interest in the Land
a. 1980 Transfer--Putnam County Property
Decedent sold the Putnam County property in August 1980 for
$1,598,100 ($700 per acre). Respondent argues that this shows
that a fee simple interest in the property was worth that amount
when decedent transferred a one-half undivided interest in the
Putnam County property to petitioner in April 1980. Petitioners
contend that a fee simple interest in the Putnam County property
was worth $1,096,000 ($464 per acre).
We believe Elmore's use of the August 1980 sale led him to
overestimate the value of the Putnam County property. The $700
per acre price exceeded the fair market value because of what
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