- 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.
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