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Based on an appraisal provided by petitioners’ expert
witness, petitioners contend that the fair market value of a one-
half interest in the Riverside property was $35,750, calculated
as follows:
$250,000 (� interest in the Riverside property)
x 22% (petitioner’s partnership interest)
$55,000
x 65% (35% minority discount)
$35,750
Petitioners’ expert testified that he relied on several
comparables within 10 miles of the Riverside property and
adjusted the value for usability of the property and for the time
of the comparable sale. He concluded that a 22-percent interest5
in the partnership’s interest in the Riverside orchard had a
value of $35,750. Petitioners contend that his appraisal is the
only credible evidence of the value of the Riverside property.
Petitioners also contend that respondent’s reliance on the
partnership’s unsupported estimate of the value of the Riverside
property is unwarranted because Smith testified that the
estimated value was not based on an appraisal.
We disagree. First, petitioners’ expert’s appraisal was a
single page of conclusions with no analysis. Second, the balance
sheets attached to the Anis partnership returns for 1995-99
stated that the book value for the Riverside property was
5 The 22-percent amount slightly understated petitioner’s
interest, which was 22.375 percent.
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