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of years between the property’s date of sale and decedent’s date
of death. After applying the time adjustment, the per-acre sale
price was adjusted by the aggregate of the waterfront and size
adjustments. The waterfront adjustment was made by comparing the
water access of the comparable property with that of DP. Mr.
Hartnett made positive and negative adjustments for water access
where he thought appropriate. The size adjustment took into
account a premium paid for smaller parcels. The greater the
difference between the acreage of DP and the comparable property,
the greater the amount of the adjustment.
4. Highest and Best Use Analysis
The estate’s position is that DP’s highest and best use on
the valuation date was mixed--recreation supported by timber
farming. Respondent contends that DP’s highest and best use on
the valuation date was as timberland since timber farming had
been the sole profitable activity of DP until decedent’s death.
We disagree with respondent.
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