-32- contention of value where the Commissioner introduced no evidence to rebut the taxpayer's expert's testimony). Respondent argues that Wiggins was not qualified to value real property because he is a business appraiser and not a real estate appraiser. Respondent contends that Wiggins provided no factual basis for his conclusions that a 20-percent discount for lack of marketability should apply. Respondent points out that Wiggins included in his report as evidence of the appropriate amount for marketability discounts a discussion of the illiquidity of privately held companies and discounts relating to sales of their stock. Respondent argues that we should give no weight to Wiggins' opinion because he did not consider the marketability of real property. Respondent argues that Wiggins' use of a 30-percent discount for lack of control for the cost of partitioning the properties was not supported by any verifiable data in his reports and far exceeds Scruby's estimated costs of partition. We disagree that we should disregard Wiggins' report because he is not a real estate appraiser. Wiggins is an experienced business appraiser who has given expert opinions in valuing fractional interests in partnerships, businesses, and real property. We believe that he correctly considered variousPage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: May 25, 2011