Estate of Duilio Costanza - Page 14

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          appraised property were in 1992.  Mr. Bollinger opined that the             
          comparative sales approach produced the most reliable data in the           
          case of a restaurant.  He determined that this approach supported           
          a value of $388,000 for the restaurant and the land upon which it           
          was located.                                                                
               Three of the four comparable sales used by Mr. Bollinger               
          were also cited in Mr. Schmidt’s 1991 appraisal (#2,3,5).  The              
          most recent of these occurred more than 3 years before the                  
          valuation date.  The fourth property (#1) used by Mr. Bollinger             
          sold in 1992, closer to the valuation date.  We do not find that            
          property comparable to decedent’s property for a number of                  
          reasons.  The fourth property had 29,140 square feet of interior            
          space, almost four times larger than the property being valued              
          (6,474 square feet).  The fourth property was located on 4.18               
          acres of land as compared to the subject property, which was                
          located on 1.9 acres.  The fourth property was zoned C-3 "highway           
          service", had a frontage of 447 feet, and contained a separate              
          retail store.  It also had 125,000 square feet of asphalt parking           
          and 5,800 square feet of concrete walks and patios.  In contrast,           
          the subject property was zoned C-1, "local business district",              
          had a frontage of only 64 feet, contained no additional retail              
          facilities, and had 10,941 square feet of parking.                          
               The principal difference between the two comparable sales              
          valuations (other than the inclusion of the 1992 sale which we              

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