-36-
We believe that Elmore overestimated the value of the estate
property because none of his comparables had as much wetlands as
the 843 acres held by the estate (79 percent). Elmore admitted
it would be difficult to develop property with a significant
amount of wetlands. The six comparables Elmore considered each
had better topography, road frontage, access to utilities, and
zoning than the 843 acres held by the estate. One comparable
sale used by Elmore was petitioner's 1986 sale of the Clay County
property that Elmore and Moses said was superior to the estate
property. The buyers of the comparable properties received
concessions from the owners (and in one case from the Government)
as a condition for paying the purchase price. We think this
shows that the prices paid for these properties were more than
the fair market value of decedent's property.
We conclude that the value of a fee simple interest in the
estate property was $750 per acre in 1992, or $632,445. Decedent
owned an undivided one-half interest in the estate property when
she died. One-half of $632,445 is $316,223. We discussed at
paragraph II-B-5, above, why we apply a 44-percent discount to
the Clay County property. We apply a 44-percent discount here
for the same reasons. We conclude that the value of the estate
property when decedent died was $177,085.
Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 NextLast modified: May 25, 2011