-25-
Lewis Timber Co. bought an additional 4,000 cords from the Putnam
County property before the Thompson partnership deeded the Putnam
County property back to decedent and petitioner in 1983.
Respondent argues that Moses' computation of the volume of timber
on the Putnam County property transferred in April 1980 is
understated by at least 7,021.45 cords (11,000 - 3,978.55).
Using Moses' assumed prices per cord of pulpwood and sawtimber,
the value of the additional timber, at $25 per cord for pulpwood,
is $175,536.25 or $74.38 per acre ($175,536.25/2,360 acres), or
at $45 per cord for sawtimber, is $315,965.25 or $133.88 per acre
($315,965.25/2,360 acres). Thus, respondent contends that Moses'
per acre value for the 1980 property should be increased to
$538.38 ($464 + $74.38), or $597.88 ($464 + $133.88).
We conclude that the value of a fee simple interest in the
Putnam County property was $1,357,000 in 1980 ($575 per acre).
Decedent gave petitioner an undivided one-half interest in the
Putnam County property. One-half of $1,357,000 is $678,500. We
discuss at paragraph II-B-5, below, to what extent we discount
the value of the Putnam County property because petitioner
received an undivided one-half interest in it.
b. 1983 Transfer--Clay County Property
Respondent argues, based on sales of comparable properties,
that the Clay County property was worth $2,083,500 ($900 per
acre) on the date of the gift in 1983. Petitioners contend that
Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 NextLast modified: May 25, 2011