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Farm at $181,973. Each RPC appraisal document indicates an
appraisal date of November 23, 1999, and states: “The purpose of
this appraisal is to estimate the market value of the subject
property’s development rights in accordance with the Delaware
Agricultural Lands Preservation Foundation.” (Emphasis omitted.)
Neither appraisal document states that it was prepared for income
tax purposes.
In April 2000, petitioners commissioned a second company,
Dover Consulting Services, Inc. (DCS), to appraise Webber Farm.
DCS valued the Webber Farm development rights at $238,007 as of
April 25, 2000. The appraisal document states that it was
prepared to “[derive] the market value of the development rights
of the property in accordance with the Delaware Agricultural
Lands Preservation Foundation provisions, and for no other use.”
The appraisal document does not state that it was prepared for
income tax purposes.2 For convenience, we refer collectively to
the RPC appraisals and the DCS appraisals as the 2000 appraisals.
On February 12, 2001, petitioners sold the development
rights to Procko Farm to DALPF for $100,487.3 On the same day,
petitioners sold the development rights to Webber Farm to DALPF
for $101,572.
2 DCS did not appraise Procko Farm in 2000.
3 All amounts are rounded to the nearest dollar.
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Last modified: May 25, 2011