- 30 - 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.Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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