Estate of Duilio Costanza - Page 21

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               Having reviewed each of their determinations, we believe               
          that a price of $48 per square foot as of December 15, 1992, is             
          appropriate.  Mr. Rexroth’s aggregate value of $44.75 reflects              
          substantial discounts that he applied to the comparable                     
          properties, based upon their allegedly superior locations.  We              
          believe that these discounts are too pessimistic.  On the other             
          hand, Mr. Bollinger’s valuation gives insufficient consideration            
          to the perpendicular orientation of the retail plaza building on            
          its lot.  This orientation had an adverse impact upon its value.            
          Having considered both reports, we believe that the retail office           
          plaza would have sold for $48 per square foot on December 15,               
          1992, or a total of $528,000.                                               
               Each party also performed a capitalization-of-earnings                 
          approach.  For petitioner, Mr. Rexroth found that the shopping              
          center building property ought to generate rentals of $8.50 per             
          square foot per year, or a total of $93,500.  From this amount,             
          he deducted $25,750 to reflect expenses and vacancies, producing            
          an annual net income $67,750.  He further concluded that a                  
          capitalization factor of 11.5 percent was appropriate, but,                 
          because he determined that the property paid too much in local              
          taxes, he increased that factor to 14.5 percent.  The presumed              
          net rentals of $67,750, capitalized at the 14.5-percent rate,               
          would produce a value of $467,500.                                          

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