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the six rental comparable properties. The map shows that
comparable property 6 is far closer to the Richard Property than
is any of the other five rental comparable properties. However,
Hulberg’s chart and other descriptive materials do not refer to
property 6. Hulberg does not enlighten us as to the
characteristics of property 6 or why he shows it on the map,
given that he does not take property 6 into account in this
evaluation.
Hulberg concluded that a prospective buyer of the Richard
Property would be able to lease it for a gross rental of $26,676
per year, with net operating income of $24,075 per year. As we
have noted, petitioner and decedent did not receive any 1992
rental income from the Richard Property. The Richard Property
produced for 1993 $10,400 income and $3,851 expenses; for 1994
$18,000 income and $2,186 expenses. Application of Hulberg’s
capitalization analysis to petitioner’s actual rental results for
these 2 years would lead to an income approach fair market value
of about $200,000, essentially similar to Atkinson’s income
approach’s $190,000. See supra table 8.
As noted, Hulberg rejected the cost approach for the Richard
Property. Although Atkinson used the cost approach, he gave
little weight to it because the other approaches “are the most
reliable as they represent verifiable market data.”
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