- 15 - on this figure, this too would leave unsubstantiated Arbor's claim to a charitable contribution deduction since the $9 million was the sale price. While we have other significant concerns with Wieme's testimony, including that he valued the building 2 months before the valuation date with no analysis of whether the applicable assumptions remained unchanged, our holding that his testimony is unreliable because of the application of an improper standard renders unnecessary further discussion of those concerns. Petitioner has failed to prove that the fair market value of Wolverine Towers was greater than the $9 million sale price.12 We sustain respondent's determination. To reflect the foregoing, Decision will be entered for respondent. 12We need not address respondent's last argument that the gift occurred on Dec. 30, 1992, not on Feb. 25, 1993, upon the closing.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
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