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residential purposes. In 1985, the city of Birmingham annexed
all of parcel B and approximately 31 acres of parcel A on its own
initiative. The annexation program was primarily designed to
increase the tax base of the city by bringing outlying commercial
properties into the city's corporate limits. The portion of
parcel A not annexed by the city of Birmingham included a strip
of land, approximately 200 feet in width, running the length of
that portion of parcel A which abuts Cahaba River Road. Despite
this annexation, however, parcels A and B remained zoned for
residential usage under the zoning classifications of the city of
Birmingham and Jefferson County as of the valuation date. In
November 1987, however, the zoning of parcel B was changed by the
city of Birmingham to a business classification. Similarly, the
zoning classification of that portion of parcel A within the
corporate limits of the city of Birmingham was changed to permit
business usage in 1991.
4. Transactions Involving Parcels A and B
In December 1976, Kovach & Associates (Kovach) offered to
purchase approximately 25 acres of trust property located north
of I-459 and west of Highway 280. The offer was for $40,000 per
acre but was subject to numerous contingencies. In December
1977, the parties entered into a purchase and sale agreement
involving 14 of the 25 acres at $43,571 per acre. This agreement
was expressly contingent on the receipt of a zoning change with
respect to the subject property. Shortly thereafter, Held, on
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