- 11 -
appraisal at the time of conversion, but Mrs. Abrams testified
that she based her professional opinion on such factors as the
sluggish real estate market, the home sales in the area as listed
in the multiple listing service, the fact that the Stewart
property was one of the most expensive houses in the county,
which would typically take months or years to sell, and the
prestigious location of the property. While Mrs. Abrams may have
some knowledge of real estate values through her experience in
the mortgage lending business, we are not required to accept such
self-serving testimony without corroborating evidence.
Niedringhaus v. Commissioner, 99 T.C. 202 (1992).
Mrs. Abrams offered no records of the alleged comparable
sales, nor any information or data therefrom and, as a
consequence, we have no way of knowing whether they would tend to
sustain or refute her stated opinion that the Stewart property’s
purported FMV in 1995 was $480,000 such that respondent’s
determination would be incorrect. On the other hand, Mr. Lilly
testified that based on his evaluation of the prior sales of
comparable properties in the area, he thought the original list
price of $484,900 in July 1995 was a little high but hoped that a
buyer would purchase the home for more than what it was worth
because of the special financing terms that petitioners were
offering.
The evidence also indicates that the Stewart property’s
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011