- 50 -
As the foregoing shows, the work of the experts in the
instant case does not give us confidence in their analyses and
also does not lead us to any clear conclusion. We are satisfied
that the fair market value of the Richard Property is
significantly more than Atkinson’s $200,000 and significantly
less than Hulberg’s $320,000.
Doing the best we can with the record presented by the
parties in the instant case, we conclude, and we have found, that
the date-of-death fair market value of the Richard Property was
$250,000.
E. Conclusion
As table 2 supra shows, we conclude that the aggregate fair
market value of the four disputed properties is $7,350,000. This
is $535,000 less than petitioner reported on the estate tax
return, $2,732,000 less than respondent determined in the notice
of deficiency, and $3,140,000 more than petitioner asserted in
the petition.
Based on our conclusions, the Christy-Hinz initial slap-dash
valuations were far better than the work product that anyone–-
whether party or expert witness–-produced once the parties got
into their confrontational mode.
We now proceed to consider the additions to tax.
Page: Previous 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 NextLast modified: May 25, 2011