- 22 - shall have no effect on the valuation of decedent’s interest for purposes of the Federal estate tax. Valuation of the Housing Partnerships Petitioner offered into evidence the expert report and testimony of Beck regarding the fair market value of decedent’s interests in the housing partnerships. Beck applied a net asset approach under which the value of each partnership was estimated to equal each partnership’s equity in its real estate assets, plus cash and accounts receivable, net of liabilities. Beck adopted the valuations of Keith and Dvorak of the real estate and subtracted the mortgage balances as of December 1989 to determine each partnership’s equity in the real property it held. Respondent did not present any expert testimony as to the value of the housing partnerships. Instead, respondent called as a fact witness David Archer (Archer), the revenue agent who had calculated the values used in respondent’s determination in the notice of deficiency, to testify regarding his calculations. There is no expert testimony in the record to support Archer’s method of computing the asset and income values of the partnerships or his decision to average the two approaches in reaching his valuation conclusion. Respondent also called Dvorak and Keith, the real estate appraisers who valued the partnerships for the equitable distribution proceedings and who were relied upon by Beck, to testify as to their valuations of eachPage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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