- 28 -
1992) and which provided in pertinent part:
The purpose of this appraisal, at your request, is to
estimate the market value of the Option to Purchase
under the Leasehold interest in the building at 15-23
North St. Clair Street, Dayton, Ohio.
* * * * * * *
After throughly analyzing the information gathered for
this assignment, in particular, the verified arms-
length transaction on the subject property that oc-
curred on July 31, 1991, it is my opinion the value of
the Option as of August 1, 1991 was $111,500.00. This
amount represents the difference between the Referenced
sale at $220,000.000 and your then current option
purchase price of $108,500.00.
Mr. Nizny prepared another letter addressed to Mr. Signom as
a partner of MHR Properties which he dated August 2, 1994 (Mr.
Nizny’s letter dated August 2, 1994) and which provided in
pertinent part:
The purpose of this appraisal, at your request, is to
estimate the market value of your Leasehold interest in
the building at 15-23 North St. Clair Street, Dayton,
Ohio.
After thoroughly analyzing the information gathered for
this assignment, in particular, the verified arms-
length transaction on the subject property that oc-
curred on July 31, 1991, it is my opinion the leasehold
value as of August 1, 1991 was $111,500.00. This
amount represents the difference between the Referenced
sale at $220,000.00 and your then current option pur-
chase price of $108,500.00.
By invoice dated August 10, 1994, Mr. Nizny billed Mr.
Signom $250 for his appraisal services. Mr. Signom paid that
invoice by check dated October 17, 1994.
On September 26, 1994, petitioners filed a joint Form 1040,
U.S. Individual Income Tax Return, for 1991 (joint return). The
Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 NextLast modified: May 25, 2011