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III. Valuation of the Subject Property
For the reasons stated above, we find that the most
persuasive evidence of the subject property’s value as of the
contribution date is the actual sale of the subject property 17
months before the contribution. We also find that the record
justifies a slight upward adjustment to account for the minor
maintenance and upkeep that occurred between the purchase date
and the contribution date. This adjustment is also warranted by
the slightly higher ultimate value conclusion of respondent’s
expert. We therefore find that the record supports a valuation
of $76,200 as of the date of contribution.
We further find that the record does not support
petitioners’ position that the subject property was worth
$475,000 at the time of contribution. As explained previously,
we found the sale by Father Stevens through the Monks Nonprofit
to petitioners was between a willing buyer and seller, not a
“distressed” sale. We also place no weight on petitioners’
accusation that the Antelope County assessor was somehow
inappropriately affected by the actual sale price and correlated
the assessed value with the sale price, rather than making an
independent determination. Finally, we cannot disregard the
13(...continued)
attempting to hit a mark of the purchase price. We find this
contention unfounded. To the extent the Antelope County assessor
considered the prior sale of the subject property when performing
the valuation, we find the assessor simply considered it, much as
we do, relevant to determine the fair market value. We do not
find that the 1997 sale of the subject property improperly
controlled the assessor’s valuation in any way.
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