Epco, Inc. and Subsidiaries - Page 23




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               Though the sewer line may be considered an income-producing            
          property in itself, the capitalization of income approach is of             
          no use to this Court unless the income can be adequately                    
          estimated at the time of valuation, the time when the completed             
          sewer line was placed in service.5  We find that the income from            
          the sewer line could not be adequately estimated by using Mr.               
          Jones' approach.  We find that the cost method of valuation is              
          appropriate in this case.                                                   
               The cost of construction of the sewer line has been fully              
          stipulated.  The cost of the sewer line connecting the treatment            
          facility to Brookshire was $350,000.  Imperial paid approximately           
          $150,000 of its own funds, and the remainder consisted of the               
          $200,000 disbursed from the escrow account.                                 
               We find that the cost of the sewer line is its fair market             
          value and hold that the cost of the sewer line, less the amount             
          petitioner paid, is includable in petitioner's gross income as a            
          contribution in aid of construction.                                        





               5    It should be noted that in Exhibit 9, received in                 
          evidence in EPCO I, petitioner estimated that the Brookshire                
          sewer line would have produced $360,157 of income discounted over           
          50 years, based on an individual $18-monthly rate for 266 trailer           
          pads.  The undated exhibit was prepared subsequent to the                   
          construction of the sewer line and does not take into account               
          either the $200,000 of contribution in aid of construction funds            
          disbursed from escrow, the possibility of potential customers               
          from Pine View, or a possible increase in the monthly sewer rate.           




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