- 36 - 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...)Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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