U.S. Court of Appeals for the Fifth Circuit, 1990

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

Jeffrey E. Griffin and Barbara B. Griffin v. Commissioner of Internal Revenue
U.S. Court of Appeals for the Fifth Circuit · Decided September 19, 1990 · Garza, Jolly, Jones, Per Curiam
911 F.2d 1124; 66 A.F.T.R.2d (RIA) 5637; 1990 U.S. App. LEXIS 16412; 1990 WL 126234 (Federal Reporter, Second Series)

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

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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