- 15 - there is specific testimony, provided that it is within the range of figures that properly may be deduced from the evidence. See Anderson v. Commissioner, 250 F.2d 242, 249 (5th Cir. 1957), affg. in part and remanding in part T.C. Memo. 1956-178. We may also be selective in the use of any portion of an expert opinion. See Parker v. Commissioner, 86 T.C. 547, 562 (1986). According to Mr. Jones' testimony and his report received into evidence, the fair market value of the sewer line using the capitalization of income method of valuation is $80,000. Mr. Jones testified that the sewer line generated annual revenue in the amount of $60,912 and that the sewer line's annual operating expenses totaled $43,303. Based on these figures, Mr. Jones calculated that the sewer line generated annual net earnings in the amount of $17,609. Mr. Jones then applied a discount rate of 22 percent because, in Mr. Jones' opinion, a willing buyer would expect a 22-percent return on this investment because of the type of risk involved. Mr. Jones did not include the $200,000 deposited in escrow or potential tap-on fees from future Pine View customers in his calculations of the proceeds from the sewer line. We have the following reservations concerning Mr. Jones' report: (1) Mr. Jones contends that the escrow funds, if they have any bearing at all on the valuation of the sewer line, should be discounted as though they were tap-on fees receivedPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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