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without cogent proof that the reported values are erroneous. See
Estate of Hall v. Commissioner, 92 T.C. at 337-338.
B. The Newport Property
At trial, Mark Cardelucci, a real estate broker, testified
about the real estate market conditions in Newport from the time
the Newport property was valued for decedent's estate tax return
until the property was later sold (the interim period). Mr.
Cardelucci testified that, with regard to the Newport property, he
believed no material change in circumstances occurred during the
interim period. Furthermore, Mr. Cardelucci testified that he
believed that the Newport property had been overvalued on the
estate tax return.
Respondent did not produce any evidence contradicting Mr.
Cardelucci's conclusions. We conclude the fair market value of the
Newport property on the alternate valuation date was $699,933.
C. The Indian Wells Property
Conversely, petitioner failed to produce any evidence that on
the alternate valuation date the fair market value of the Indian
Wells property equaled its sales price 20 months later. We
conclude that petitioner has failed to provide cogent proof showing
that the amount reported on decedent's estate tax return was
erroneous. We conclude the fair market value of the Indian Wells
property as of the alternate valuation date was $280,000.
In reaching all of our holdings herein, we have considered all
arguments made by the parties, and, to the extent not mentioned
above, we find them to be irrelevant or without merit.
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