- 51 -
property, in the case of Parcel 1 he instead selected the
adjusted per acre value of a single comparable in reaching his
indicated value, on the grounds that this comparable was "the
least adjusted comparable sale". Had Mr. Reyman taken the
average of the six, his indicated value for Parcel 1 would have
been approximately $2,150 per acre, rather than the $2,075 per
acre value he derived from using a single comparable. Other than
the bald claim that the single comparable he chose was "least
adjusted", Mr. Reyman provides no explanation for his departure
from the methodology used for the three other parcels. We are
not persuaded that such a departure, which reduces the value
estimate for Parcel 1 by more than $10,000, is justified. We
accordingly conclude that the best indication of Parcel 1's value
from this record results from averaging the adjusted values of
the six comparables identified by Mr. Reyman.
Values Before Fractional Discounts
Mr. Reyman concluded that Parcel 4 had a value of $198,000
on the valuation date, whereas respondent determined the value at
$198,876. Given the proximity of these results, we conclude the
estate has not met its burden of showing respondent's
determination to be incorrect and therefore sustain it.
Mr. Reyman estimated that Parcel 1 had a value of $281,800
on the valuation date. As discussed above, we conclude that Mr.
Reyman should not have made a $150 downward adjustment to one of
Page: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 NextLast modified: May 25, 2011