-26- 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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26
Last modified: May 25, 2011