James V. Abrams and Laurie Abrams - Page 12




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          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                






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