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alone, i.e., the lower range of indicated value, we reject that
explanation. Mr. Gilman did not select any comparable properties
that would provide an upper range of indicated value, such as
ranches in the Santa Ynez Valley. We are unable to determine how
much weight Mr. Gilman gave the various comparable properties
because of the lack of an adjustment grid. Ultimately, these
flaws lead us to reject the per-acre values indicated by his
report. See Buffalo Tool & Die Manufacturing Co. v.
Commissioner, 74 T.C. 441 (1980).
C. Respondent's Expert
Mr. Hamel also used the Sales Comparison Approach to
determine the fair market value of decedent's interests in the
ranch properties. In contrast to Mr. Gilman, who valued each
parcel individually, Mr. Hamel valued the four Nipomo properties
as if they were one integrated ranch property of 2,242 acres.13
Mr. Hamel's selection of comparable ranch properties
included 12 sales occurring before the valuation date and four
sales occurring within 3 years thereafter. Mr. Hamel's report
contains photos of the subject and comparable properties,
topographic and plat maps, and an adjustment grid reflecting
adjustments for parcel size and market timing. In the text of
13Petitioner did not criticize Mr. Hamel on this point. We
treat this as a concession that the integrated ranch approach is
appropriate in this case for the Nipomo properties, with the
exception of parcel 10.
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