§2.06 Valuation of Real Property

The valuation of real property is governed by Evidence Code §§810 et seq. [EC §810(a).] There are three methods for valuing real property [Marriage of Folb (1975) 53 CA3d 862, 868, disapproved on other grounds in Marriage of Fonstein (1976) 17 C3d 738, 749 n5]:

• A market approach [see EC §§811, 815, 816],
• An income approach [see EC §819], or
• A cost approach [see EC §820].

The value of real property may be shown only by the opinions of [EC §813(a)]:

• An expert qualified to express such an opinion, or
• The owner or the spouse of the owner of the property or property interest being valued.

An expert's opinion must be based on matter he or she perceived or personally knows, or was made known to him or her at or before the hearing, whether or not admissible. The basis for the opinion must be of a type that an expert reasonably may rely on in forming an opinion on valuation. [EC §814.]