Jeffrey E. Griffin and Barbara B. Griffin v. Commissioner of Internal Revenue

Fifth Circuit

Jeffrey E. Griffin and Barbara B. Griffin v. Commissioner of Internal Revenue

911 F.2d 1124, 66 A.F.T.R.2d (RIA) 5637, 1990 U.S. App. LEXIS 16412, 1990 WL 126234

Court of Appeals for the Fifth Circuit·Decided September 19, 1990·No. 89-4789·Published

Opinion

PER CURIAM:

This court is persuaded that the Tax Court did not clearly err in computing the value of the conservation servitude created by the taxpayers m this case. The Tax Court appears to have rendered its decision in Dorsey, 1990 CCH Tax Rpts. 592 (5/17/90), based upon its independent evaluation of the evidence and expert opinions presented at trial, which differed from the evidence and expert opinions in this case. We cannot say whether the court’s approach in Dorsey or in Griffin yielded superior results or whether either approach is “wrong”, given the inexactitude of the art of real estate appraisal.

The judgment of the Tax Court is AFFIRMED.

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PER CURIAM:

This court is persuaded that the Tax Court did not clearly err in computing the value of the conservation servitude created by the taxpayers m this case. The Tax Court appears to have rendered its decision in Dorsey, 1990 CCH Tax Rpts. 592 (5/17/90), based upon its independent evaluation of the evidence and expert opinions presented at trial, which differed from the evidence and expert opinions in this case. We cannot say whether the court’s approach in Dorsey or in Griffin yielded superior results or whether either approach is “wrong”, given the inexactitude of the art of real estate appraisal.

The judgment of the Tax Court is AFFIRMED.

Jeffrey E. Griffin and Barbara B. Griffin v. Commissioner of Internal Revenue, 911 F.2d 1124, 66 A.F.T.R.2d (RIA) 5637, 1990 U.S. App. LEXIS 16412, 1990 WL 126234 (5th Cir. 1990).

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Opinion

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