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in excess of the $25,000-per-acre value now advocated by
petitioner.
Petitioner employed DeVoe, an appraiser, to ascertain the
value of decedent’s interest in the Busch property for purposes
of reporting it on the estate’s tax return. DeVoe’s report was
attached to the estate tax return and employed what he described
as a “Market Data Approach” to value the property. That same
approach has also been described as a comparable sales approach
and involves the collecting of information on comparable and
generally contemporaneous sales of like property in the general
locale of the subject property.
DeVoe relied on nine sales with per-acre prices ranging from
$21,612 to $445,872. One of the sales referenced by DeVoe was
the 1986 sale of 16.66 acres of the Busch property to Pleasanton
for $103,158 per acre. In five of the nine sales, the approval
to develop had been obtained and the per-acre price ranged from
$152,439 to $445,872. In one situation, partial development
approval had been obtained and the per-acre price (based on full
acreage even though all of it was not usable) was $53,043. The
remaining two sales, for $21,612 and $29,520 per acre, concerned
situations where no approval for development had been obtained.
Other than the 1986 sale of the 16.66-acre Busch parcel, the
sales used by DeVoe occurred during the period April 1989 through
May 1993.
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