-16-
B. Respondent’s Expert’s Appraisal
Respondent’s expert’s appraisal, which found that the fair
market value of the subject property at the time of contribution
was $90,000, corroborates the purchase price as a persuasive
indication of the fair market value of the subject property.
Respondent engaged William C. Fischer (Mr. Fischer) to perform an
appraisal of the subject property as of the date of contribution.
Mr. Fischer, who has been a real estate appraiser for 45 years,
is MAI8 certified and Nebraska certified. Mr. Fischer completed
60 hours of education every 3 years to retain his MAI
certification. During his career, he has performed between 4,500
to 5,000 independent appraisals of commercial properties in 15
different States. In addition, Mr. Fischer has experience in
appraising religious property, which is typically considered
special use property, including approximately 16 to 20 churches
as well as a mission area. Mr. Fischer also has experience in
appraising special use property, such as event centers and school
buildings.
We find Mr. Fischer’s appraisal to be thoughtful and
credible, and it closely corroborates the prior sale in
determining the fair market value of the property at the time of
8MAI is a designation awarded to qualifying members of the
American Institute of Real Estate Appraisers and within the
appraisal community is viewed as the most highly regarded
appraisal designation. See Estate of Auker v. Commissioner, T.C.
Memo. 1998-185.
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