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was contiguous with DP and sold for $1.1 million. Mr. Hartnett
estimated that the values of the improvements and marketable
timber were $150,000 and $425,000, respectively.
On the basis of the two principal sales of comparable
properties, Mr. Hartnett determined a per-acre value of $1,975
for DP, which totaled $4,137,862 (2,095.12 acres x $1,975/acre).
He then added $100,000 for the estimated value of all
improvements to DP and concluded that the estimated market value
of DP was $4,237,862, which he rounded to $4,238,000.
Respondent contests the use of the Birchwood sale on the
basis that it was part of a section 1031 exchange and it was not
in the “prestigious ACE Basin”. Respondent argues that the
public records reveal that the total value of the property
transferred by the buyer was more than the amount Mr. Hartnett
included in his report. We agree.
The facts regarding the Birchwood sale are insufficient for
us to use it as a comparable property because we do not know the
value of the 2,344 acres of land transferred by the purchaser.
Mr. Hartnett could provide only the value of the merchantable
timber thereon. Given this shortcoming, we do not believe that
the Birchwood sale is relevant.
In contrast, we find the White House Plantation sale is
relevant. The White House Plantation is contiguous with DP, and
the sale occurred only about 2 years before decedent’s death.
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