Estate of Pearl I. Amlie, Deceased, Rodney B. Amlie, Executor - Page 51

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          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            






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