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C. Petitioners’ Expert’s Appraisal
We now address the conclusions of petitioners’ expert, who
determined the subject property’s value to be $475,000, on the
date of contribution. We find this valuation conclusion
problematic and give it considerably less weight. TRRC engaged
Mr. White to perform an appraisal of the subject property as of
the contribution date. Mr. White is a certified real estate
appraiser located in Neligh, Nebraska, where he has lived his
entire life. He has had his appraiser’s license since 1976 and
his general certified appraiser’s license since 1993.
The evidence in this case does not fully establish the
independence of Mr. White. TRRC, not TRY, retained Mr. White, at
the suggestion of Mr. Archbold. It was not explained at trial
why the donee, rather than the donor, hired the appraiser, and no
one testified why or how Mr. White was the appraiser chosen.
Lacking any evidence to answer these questions, we cannot
evaluate and satisfy ourselves that Mr. White’s valuation opinion
was truly independent. We are troubled by the circumstances
under which Mr. White was retained and also by his analysis and
conclusions. These concerns lead us to give significantly less
weight to Mr. White’s conclusions of value.
Mr. White used two of the three traditional approaches to
value in his appraisal. As with Mr. Fischer’s appraisal for
respondent, Mr. White also did not rely upon the income approach
as the subject property was not income-producing property.
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