- 46 - 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 thePage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
Last modified: May 25, 2011