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access, Mr. Middleton grouped similar tracts for valuation
purposes. Using the comparable properties with similar
attributes, he determined the combined value of the smaller
tracts was $226,000 on the valuation date.
Mr. Middleton calculated the total appraised land value of
DP as follows:
Main tract value--1,961.3 acres $2,500,000
Improvement value 100,000
Combined value of the five small tracts 226,000
Total 2,826,000
Rounded to 2,825,000
b. Timber Appraisal
Mr. Pellum determined the value of standing merchantable
timber, and his report was attached to the estate tax return.
Mr. Pellum did not testify at trial. In his report, Mr. Pellum
used stands to identify specific forested acres on DP and
determined the quality (pine sawtimber, chip-n-saw, pine
pulpwood, hardwood sawtimber, and hardwood pulpwood) and volume
of the timber in each stand. Using the Timber Mart-South, South
Carolina Stumpage Prices, 2nd Quarter 1999, which provided per-
ton prices for different timber qualities, he calculated the
value of the merchantable timber on DP’s 1,481 forested acres.
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