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II. Valuation Methodology
At trial, petitioner presented the testimony of Terry Lloyd,
C.P.A., C.F.A., as an expert valuation witness. Mr. Lloyd
prepared an expert witness report in accordance with Rule 143.
The record also contains the expert report of John E. Camp,
C.P.A./A.B.V., C.F.A., of Ferguson, Camp & Henry, whose report
provided the valuation used in the preparation of petitioner’s
1999 Federal income tax return (1999 return). In addition, in
evidence is a draft expert report by Jonathan E. Kemmerer,
C.P.A., dated June 5, 1996, and a report by James Kowis, P.E., of
James Kowis Consulting, dated November 10, 2003. Mr. Kemmerer’s
expert report was submitted in draft form, and is of limited use
to reach a final valuation conclusion.
Respondent presented the testimony of Gregory E. Scheig,
C.F.A., C.P.A., of CBIZ Valuation Group, Inc., as an expert
valuation witness. Mr. Scheig prepared an expert witness report
in accordance with Rule 143. Mr. Lloyd, Mr. Camp, and Mr. Scheig
in their respective expert reports valued petitioner’s water
right in separate components: (1) The estimated 100,000 acre-foot
portion of petitioner’s water used for irrigation, (2) the 35,000
acre-foot portion of petitioner’s water involved in the Corpus
Christi transaction, and (3) the estimated 33,000 acre-foot
portion of petitioner’s water that was neither used for
irrigation nor involved in the Corpus Christi transaction. Mr.
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