Carrie H. Suchar, Transferee, et al. - Page 24

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          Deborah, from Richard and Marilou for $45,000, occurred between             
          related parties and was not based on any fair market valuation              
          thereof, but rather was based on the amount Marilou was willing             
          to accept to relinquish her one-half interest in the farm                   
          acreage;                                                                    
               (5)  As set forth in respondent’s expert’s report, sales of            
          comparable properties located in the vicinity of the subject                
          properties support respondent’s expert’s fair market value for              
          the farm acreage of $176,000;                                               
               (6)  Petitioners’ expert real estate appraisal of the farm             
          acreage was based on properties not located within the reasonable           
          vicinity of the subject properties and located in less desirable            
          areas;                                                                      
               (7)  Neither party submitted an expert appraisal of the                
          residence acreage, and the parties appear to accept the $16,984             
          in cash that Carrie received in connection with the May 2000 sale           
          of the residence acreage as indicative of the fair market value             
          of the residence acreage, as of September 9, 1998, and of the               
          fair market value of Richard’s one-half interest therein that was           
          transferred to Carrie; and                                                  
               (8)  With regard to the fair market value of Richard’s one-            
          half interest in the 20-acre carve out that he transferred to               
          Carrie in 1998, respondent’s expert appraised it at $10,000, and            
          petitioners’ expert did not opine as to its value.                          






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