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          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 each                       
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