- 9 -
particular element of valuation, and another expert may be
persuasive on another element. See Parker v. Commissioner, 86
T.C. 547, 562 (1986). Consequently, we may adopt some and reject
other portions of expert reports or views. See Helvering v.
National Grocery Co., 304 U.S. 282 (1938).
There are generally three kinds of valuation methods used to
determine fair market value of real property: (1) The comparable
sales method, (2) the income method, and (3) the cost method.
See Marine v. Commissioner, 92 T.C. 958, 983 (1989), affd.
without published opinion 921 F.2d 280 (9th Cir. 1991).
Property Valuation
Petitioner is attempting to show that the fair market value
of the Kmart property is $5,300,000, the same amount that was
used to compute the value reported on the Estate’s tax return.
Petitioner’s primary trial expert reviewed the appraisal used in
connection with the estate tax return. He relied heavily on the
two income approach methods of valuation and calculated a
$5,300,000 fair market value for the Kmart property.
Respondent’s expert used one of the income approach methods and
the comparable sales approach. His approaches resulted in fair
market values ranging from $5,700,000 to $6 million. Finally,
petitioner’s rebuttal expert reviewed respondent’s expert’s
report and concluded that the fair market value was just over
$5,400,000.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011