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his report, Mr. Hamel stated that he relied more heavily upon 10
of the 16 comparable sales for his opinion.
Of those 10 properties, sale prices per acre ranged from
$600 (a 3,500-acre parcel known as the Biddle Ranch, sold almost
3 years after the valuation date) to $1,996 (a 248-acre parcel
located east of Nipomo and roughly 10 miles to the northwest of
decedent's Nipomo properties). Mr. Hamel adjusted the latter
sale downward by $500 to account for the small size of the parcel
relative to the combined size of the Nipomo properties. Mr.
Hamel added $388 per acre to the Biddle Ranch sale as a market
timing adjustment. After adjustment, these properties were
valued at $988 and $1,496, respectively. Similar adjustments for
size and market timing were made to a few other comparables.
From his data, Mr. Hamel concluded that the value of a fee simple
interest in the Nipomo properties was $1,200 per acre.
Petitioner criticized Mr. Hamel’s selection of comparable
properties, claiming his selection resulted in an overestimation
of the fair market value of decedent’s ranch properties. We
agree with this criticism. Mr. Hamel's selection of comparable
properties included properties in the Santa Ynez River Valley,
yet no location adjustment was indicated for those properties.
In fact, no location adjustment was made for any of Mr. Hamel's
comparable properties, including those sold to Hollywood
celebrities who presumably were not interested in using the
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