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Mr. Brown appraised the houses in 1995, 12 years after
the sales at issue, using both the comparable sales and
cost methods. Mr. Brown testified that he inspected the
exterior of each house appraised, and that he reviewed the
records at the Harris County Appraisal District and at Baca
Landata, a company located in Houston, Texas, which assists
taxpayers in dealing with the Harris County Appraisal
District.
Mr. Brown's approach is illustrated by his appraisal
of the property at 3518 Tower Hill Lane. That property
is located on a cul-de-sac in the Northcliffe Manor
subdivision approximately 12 miles northwest of downtown
Houston. It consists of a 1,331-square-foot house and
garage built in 1983 on a 5,775-square-foot lot.
Mr. Brown employed the comparable sales approach and
the cost approach to value this property. He identified
four comparable sales, two sales of comparable houses in
1983 and two sales in 1987. He then used a "comparable
sales adjustment grid" to adjust the sale price of each of
the comparables to account for differences in the date of
sale, location, lot size, size of the improvements, and
year built. After determining the adjusted fair market
value of each of the comparables, Mr. Brown divided the
adjusted value of each property by the square footage of
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