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conclusions of respondent’s expert, an MAI certified appraiser
with significant experience appraising property similar to the
subject property.
Instead, we have relied on three evidentiary bases showing
the determinations of value of the subject property, all of which
we find to be credible. The actual sale price, respondent’s
expert’s valuation, and the Antelope County assessment are
reasonably close in their ultimate conclusions of value.
Petitioners’ valuation is the only outlier and is based upon an
expert opinion we find dubious and not well supported by
valuation methodology. We find that Mr. Fischer’s report
provides a better indication of the fair market value. It is
well reasoned and thorough. In addition, it is consistent with
the previous purchase of the subject property 17 months before
the valuation date, and the assessed value of the subject
property corroborates this value.
Accordingly, based on our review of all the valuation
evidence, giving due consideration to our observation at trial of
the witnesses for both parties and considering their testimony
and the expert reports, we conclude that the fair market value of
the subject property was $76,200 on the date of contribution. We
therefore sustain respondent’s determinations in each deficiency
notice regarding the fair market value of the subject property.
To reflect the foregoing,
Decisions will be entered
for respondent.
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