Jerrold E. and Helen C. Arbini - Page 21

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          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.                                                        

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