4.4.2.4.1. Prior Sales of the Same Property.Prior sales of the same property, if unforced, arm’s-length, for cash or its equivalent, and reasonably recent to the date of valuation, are extremely probative evidence of market value.464 Accordingly, the appraiser must determine what the owner paid for the property being appraised.465 In analyzing prior sales, adjustments may be necessary to account for changes in market conditions, transaction conditions, or other factors.466 Prior sales of the same property are not categorically entitled to more weight than sales of other comparable properties: the relative importance of each must be analyzed under the particular facts of the appraisal assignment.467 

Each appraisal report must state and support the consideration accorded to the immediate past sale of the property under appraisal, even if the appraiser concludes the circumstances of the prior sale may have rendered it irrelevant to the determination of the market value as of the date of valuation.468 An unsupported statement that the sale did not represent market value, or was not an arm’s-length transaction is not sufficient: as the Eighth Circuit admonished, disregarding a prior transaction without first contacting the participants “to ascertain their motives” would be based on “nothing but speculation[.]”469 

These requirements reflect the federal courts’ recognition that considering a property’s sale and use history is simply good practice in “forming an intelligent opinion” of its value.470 Because a prior sale of the property being acquired is extremely pertinent, such evidence has been allowed even when a considerable period of time has elapsed between the sale and the date of valuation.471 The sales history should also include prior transactions involving a portion of the property under appraisal, such as sales of individual parcels that were subsequently assembled to form the single property under appraisal.472