Richard J. and Melodie D. McKeever - Page 36




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            Petitioners spent $6,546 on corrals and arenas to improve the                              
            ranch for use in their horse activity.  The record does not                                
            reflect clearly the total cost for all the improvements.  As of                            
            July 14, 1998, the fair market value of the ranch, based on its                            
            use as a horse ranch and residence, was $409,000.                                          
                  As of July 1998, petitioners’ horses had a fair market                               
            value of $307,000.  Respondent’s expert, Deborah McMahon-King,                             
            valued the herd at $289,500, while petitioners’ expert, Dr.                                
            Cortelezzi, valued the herd at $496,500.  Both reports were                                
            conclusory.  Ms. McMahon-King’s report offered at least some                               
            explanation for her valuation of specific horses, however, and we                          
            found her report more reliable than Dr. Cortelezzi’s report.  See                          
            Buffalo Tool & Die Manufacturing Co. v. Commissioner, 74 T.C. 441                          
            (1980); Estate of Hinz v. Commissioner, T.C. Memo. 2000-6 (slip                            
            op. at 27 n.15) (citing 15 Mertens, Law of Federal Income                                  
            Taxation, sec. 59.08 at 22 (1999)).                                                        
                  Ms. McMahon-King did not value three horses in the herd, La                          
            Sensacion de Norco, Presumida de Besilu, and Adelita LaCe.  Dr.                            
            Cortelezzi valued these horses at $6,000, $15,000, and $3,500,                             
            respectively.  We find that the horses had values of $6,000,                               
            $10,000, and $1,500, respectively, for a net addition of $17,500                           
            to Ms. McMahon-King’s figure of $289,500.11                                                


                  11Our findings with respect to Sensacion de Norco and                                
            Presumida de Besilu are based upon Ms. McMahon-King’s valuation                            
                                                                         (continued...)                





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