J.C. Shepherd - Page 26




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          in substantial agreement that the leased land should be valued as           
          of the time the subject gift was made as the sum of:  (a) The               
          present value of the projected annual rental income from the                
          lease, plus (b) the present value of the reversion.  The parties            
          disagree, however, about numerous assumptions made by the experts           
          at each step of the valuation methodology.  We address these                
          disagreements below.                                                        
               1.  Present Value of Projected Lease Rents                             
               The value of the lease income stream may be estimated by               
          determining the rental payments petitioner was receiving at the             
          time of the gifts, then projecting those rents into the future              
          based upon an anticipated growth rate, and finally discounting              
          the future rents payments to a 1991 present value using an                  
          appropriate discount rate.  See Saunders v. United States, supra;           
          see also Estate of Barge v. Commissioner, T.C. Memo. 1997-188               
          (using an income capitalization approach to value gift of 25-               
          percent undivided interest in timberland); cf. Estate of Proctor            
          v. Commissioner, T.C. Memo. 1994-208.  We estimate the present              
          value of the projected income stream from the lease based upon              
          events, expectations, and market conditions as they existed at              
          the time of the gifts in August 1991.                                       
                    a.  Projected Annual Income From the Lease                        
               It is undisputed that when petitioner made the gifts, the              
          remaining term of the lease was approximately 32 years.  The                
          parties have also stipulated the actual rental amounts received             




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