- 52 - the comparables for Parcels 1, 2, and 3, and the elimination of this adjustment raises the indicated value by $25 per acre, or $3,396 for Parcel 1. We also conclude that Mr. Reyman should have utilized the average of the adjusted values of his six comparables for Parcel 1, rather than adopting one comparable. A modification to employ the average raises the indicated value for Parcel 1 by $75 per acre, or $10,187. We accordingly find that the estate has shown respondent's determination to be incorrect, and that the value of Parcel 1 on the valuation date was $295,383. Mr. Reyman estimated that decedent's seven-twelfths interest in Parcel 2, without regard to any discount for a fractional interest, had a value of $195,300 on the valuation date. He further estimated that decedent's one-half interest in Parcel 3, without any fractional interest discount, had a value of $185,000 on the valuation date. After removing the unjustified $150 downward adjustment to one comparable, the value of Parcel 2 increases $2,325 (7/12 of $25 per acre) to $197,625, and the value of Parcel 3 increases $2,917 (1/2 of $25 per acre) to $187,917. We consider the impact of any fractional interest discounts below. Impact of Fractional Interests Since decedent held only seven-twelfths and one-half interests in Parcels 2 and 3, respectively, the estate arguesPage: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Next
Last modified: May 25, 2011