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compliance with Rule 143(f). We sustained the objection insofar
as we required Agent Puntenney to confine his testimony to a
description of his methodology.
Upon review of Agent Puntenney's testimony and related
documents, we find his valuation methodology theoretically sound.
We note that his basic approach was similar to that of the
estate's expert; namely, a comparison of sales of comparable
properties with adjustments for corn suitability ratings
(discussed infra). We also note, however, that Agent Puntenney's
sales comparison approach required the selection of comparable
properties, an exercise of judgment involving the application of
specialized knowledge generally considered expert opinion. The
comparables chosen by Agent Puntenney indicated an average per-
acre value of $1,513, whereas the comparables chosen by the
estate's expert indicated an average value of $1,397 per acre.
The selection of comparables involves real estate valuation
expertise that Agent Puntenney was not shown to possess. Thus,
while his conclusions are supportable, we conclude that they are
less reliable than those of the estate's expert.
The estate bears the burden of proving that the valuation
determinations in the notice of deficiency are incorrect. Rule
142(a). The estate relies on the expert reports and testimony of
Mr. Reyman. Mr. Reyman concluded that, in light of the active
market in agricultural real estate in Iowa, the sales comparison
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