- 17 - When performing the present value calculations, Ms. Simons assumed two properties were marketed and sold every 4 months. Ms. Simons used an average sales price for each of the properties and discounted this price back to the date of decedent’s death based on the time required to sell the properties. Because the first two properties were assumed to sell within a normal marketing period of 4 months, Ms. Simons did not discount these prices back to present value. 3. Appropriate Blockage Discount The parties disagree as to the appropriate method for determining a blockage discount. Although we do not find anything inherently wrong in Ms. Simons’ approach, we believe that Mr. Talmage’s approach is the better determiner of the appropriate blockage discount to apply in the present case. Cf. Estate of Auker v. Commissioner, T.C. Memo. 1998-185 (wherein we adopted an approach similar to Ms. Simons’ approach). Mr. Talmage’s report is well reasoned and based on reliable statistical data. We find that 6 months was a reasonable marketing period for properties in the Marina District. Not only do the MLS and Comps data support such a finding, but we believe that Ms. Simons’ report also does. Ms. Simons’ report concludes that it would take 3 to 4 months to list and either sell or escrow a property. Mr. Talmage’s marketing period begins with the listing and endsPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011