Roger and Sharon Wortmann, et al. - Page 26

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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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