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Busch property as of the June 1994 agreement date was $15
million, irrespective of whether a single or dual closing
occurred. Geller’s approach was an attempt at reaching a present
value of the June 1994 agreement. By using a present value
technique, Geller acknowledges that the June 1994 agreement was
not a cash sale. Respondent relies on Geller’s value as
reflecting an actual and/or comparable sale that supports
respondent’s value determination in the deficiency notice.
Respondent directs our attention to the fact that Geller’s $15
million value is slightly in excess of the gross value determined
in the deficiency notice. It does not appear that respondent
discounted for the fact that decedent held a partial interest.
Both parties used acceptable methodologies for valuing the
subject property. Although the methodology was appropriate, we
do not agree with all of the techniques, modifications, and/or
discounts that were used to affect the ultimate proposed values.
Hulberg, petitioner’s expert, begins with comparables for
residential development property and, by means of extremely large
discounts, reduces the comparable to $25,000 per acre. In this
way, Hulberg advances a value for the Busch property that,
essentially, represents a value for unimproved farmland. Hulberg
expressed the view that the highest and best use of the Busch
property was for residential development and that comparable
sales provide the best method to value unimproved land. He then
effectively voided those views by using extraordinary discounts
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