- 21 -
consumed in the process of manufacturing items of jewelry. See
id. at 883.
In Akers v. Commissioner, 799 F.2d 243 (6th Cir. 1986),
affg. T.C. Memo. 1984-490, the court relied on our reasoning in
Anselmo v. Commissioner, 80 T.C. 872 (1983), in holding that a
tract of land containing approximately 1,261 acres should be
valued based on comparable sales of other tracts of land
containing over 1,000 acres. See Akers v. Commissioner, supra at
244-246. The court rejected the taxpayers’ contention that the
value of the property should be determined based on the value of
the property as if it was subdivided into 24 lots averaging 52.5
acres each. See id. at 245. The court reasoned that the
“ultimate consumer” of a 50-acre lot would normally not have the
time, inclination, expertise, or capital to buy the entire
property with a view to subdivision and sale of the excess. Id.
at 246. The court distinguished its situation from one where
property consists of multiple items available for sale, by
explaining that the property in the case at hand was not
subdivided and ready for immediate sale in the retail market.
See id. at 247. We find the reasoning in Anselmo v.
Commissioner, supra, and Akers v. Commissioner, supra, applicable
to the instant case.
Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 NextLast modified: May 25, 2011