Estate of Rebecca A. Wineman - Page 30




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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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