Estate of Lea K. Hillgren, Deceased, Mark Hillgren, Executor - Page 46

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          considered that a hypothetical willing buyer would know of the              
          existence of the BLA.                                                       
               Raynor Klaris (Klaris) and John A. Thomson (Thomson) of                
          Klaris, Thomson & Schroeder, Inc., prepared two appraisal reports           
          for respondent (respondent’s appraisal).  Klaris has been in the            
          appraisal business since 1961 and is a Senior Accredited Member             
          of the American Society of Appraisers with a specialty in                   
          business valuations.  Thomson has been an appraiser since 1976              
          and received his Accredited Senior Appraiser designation in                 
          business valuations and intangible properties in 1982.  Thomson             
          is also a real estate appraiser.  Both of respondent’s appraisals           
          assumed that the BLA affected only the University property and              
          not the Orange County properties.  As in Estate of Hall v.                  
          Commissioner, supra, although respondent’s experts were                     
          qualified, they were hindered in their valuation by respondent’s            
          incorrect instructions regarding the effect of the BLA.                     
               1.  The University Property                                            
               The parties agree that the undiscounted value of decedent’s            
          interest in the University property is $1,074,131.  Based on the            
          terms of the BLA, Hillgren held a 25-percent lender interest in             
          the net proceeds from sale or refinancing of the University                 
          property.  The Hoffman appraisal therefore reduced the value of             
          the University property by 25 percent to represent Hillgren’s               
          interest.  Respondent’s appraisal also reduced the value of the             






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