James H. Japhet - Page 6




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                         Comparable     Income    Cost method   Estimated             
                        sales method    method                    value               
          Petitioners’  --     --     --  1$106,000                                   
          returns,                                                                    
          petitions,                                                                  
          and brief                                                                   
          Deficiency                                                                  
          notices and   --     --     --   139,900                                    
          answers                                                                     
          Petitioners’  $106,000      $104,390   $106,403      106,000                
          expert Glen                                                                 
          Respondent’s  139,900       138,700    147,000       139,900                
          expert Kurek                                                                
               1 Petitioners reported on their returns and asserted in the            
          petitions that the fair market value of the apartment building              
          was $105,465.  On brief, they contend that its value was                    
          $106,000.                                                                   
          C.   Petitioners’ Experts                                                   
               1.   Wolff                                                             
               Wolff appraised the apartment building in August 1991 for              
          NCNB Bank for refinancing purposes.  He estimated that its fair             
          market value was $85,000.  He used 7527 Windsor Oaks as a                   
          comparable property.  7527 Windsor Oaks had the same size and               
          number of rental units as the apartment building and was sold in            
          January 1991 for $79,000.  Wolff testified that the value of the            
          apartment building could reasonably have increased to $106,000 in           
          1993.                                                                       
               2.   Glen                                                              
               Glen inspected the apartment building in May 1997.  He                 
          estimated that its fair market value was $106,000 as of August              






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